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EFCO TOOL CO. v. COMMISSIONER

Docket No. 13380-82.

81 T.C. 976 (1983)

EFCO TOOL COMPANY, A MICHIGAN CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 15, 1983.

Attorney(s) appearing for the Case

Robert A. Clemente,* for the petitioner.

Robert T. Hollohan and Thomas M. Cryan, for the respondent.

OPINION

DAWSON, Chief Judge:

This case was assigned pursuant to section 7456(c) and (d), Internal Revenue Code of 1954, as amended, and Delegation Order No. 8 of this Court, 81 T.C. VII (July 1983), to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on respondent's motion to dismiss for lack of jurisdiction. After a review of the record, we agree with, and adopt, his opinion which is set forth below.

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