Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
This case was assigned to and heard by Special Trial Judge, Joan Seitz Pate, pursuant to section 7456(c) and (d) of the Code and General Order No. 8 (81 T. C. XXIII) (1983) and Rules 180 and 181.
Opinion of the Special Trial Judge
PATE, Special Trial Judge...
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