Memorandum Opinion
DRENNEN, Judge:
This case was assigned to and heard by Special Trial Judge Daniel J. Dinan pursuant to the provisions of General Order No. 6, 69 T.C. XV (1978). The Court agrees with and adopts the Special Trial Judge's Opinion which is set forth below.
Opinion of the Special Trial Judge
DINAN, Special Trial Judge:
Respondent determined a deficiency in petitioner...
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