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GJOEN v. COMMISSIONER

Docket No. 26589-81.

45 T.C.M. 892 (1983)

T.C. Memo. 1983-114

Ralph Jacob Gjoen and Patricia Anne Gjoen v. Commissioner.

United States Tax Court.

Filed March 3, 1983.

Attorney(s) appearing for the Case

John J. Morrison, for respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Randolph F. Caldwell, Jr., for hearing on respondent's motion for summary judgment, pursuant to section 7456(c), Internal Revenue Code of 1954, and Rule 180 et seq. of this Court's Rules of Practice and Procedure. This Court agrees with and adopts the Special Trial Judge's opinion which is set out herein below.

Opinion of the Special Trial Judge...

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