Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
This case was assigned to Special Trial Judge Joan Seitz Pate pursuant to section 7456 of the Code and Rules 180 and 181 of the Tax Court Rules of Practice and Procedure.
The Court agrees with and adopts her opinion which is set forth below.
Opinion of the Special Trial Judge
PATE, Special Trial Judge:
Respondent determined deficiencies...
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