OPINION
DAWSON, Chief Judge:
This case was assigned pursuant to section 7456(c), I.R.C. 1954, as amended, and Delegation Order No. 8 of this Court, 81 T.C. XXV (1983), to Special Trial Judge Francis J. Cantrel for the purpose of considering and ruling on petitioners' "Motion for Leave to Reargue and for Reconsideration of the Court's June 30, 1983 Order" filed herein. After a review of the record, we agree with and adopt his opinion which is set forth...
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