Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
This case was assigned to Special Trial Judge Lee M. Galloway for hearing on respondent's motion for partial summary judgment under Rule 121, Tax Court Rules of Practice and Procedure. The Court agrees with and adopts his opinion which is set out herein below.
Opinion of Special Trial Judge
GALLOWAY, Special Trial Judge:
This case is before the...
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