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INCOLLINGO v. COMMISSIONER

Docket No. 2080-80.

45 T.C.M. 350 (1982)

T.C. Memo. 1982-727

Robert R. Incollingo and S.F. Incollingo v. Commissioner.

United States Tax Court.

Filed December 20, 1982.

Attorney(s) appearing for the Case

Robert R. Incollingo, pro se, Cherry Hill, N.J. Russell K. Stewart, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

This case was assigned to Special Trial Judge John J. Pajak pursuant to the provisions of section 7456(c) of the Code1 and Rules 180 and 181.2 The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

PAJAK, Special Trial Judge:

Respondent determined a deficiency in petitioners...

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