Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
This case was assigned to Special Trial Judge Peter J. Panuthos for the purpose of considering and ruling on respondent's Motion for Judgment on the Pleadings pursuant to Delegation Order No. 8 of this Court, 81 T.C. XXV (1983). The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Special Trial Judge
PANUTHOS, Special Trial Judge:
This case...
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