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McQUADE v. COMMISSIONER

Docket No. 22429-81.

84 T.C. 137 (1985)

ELANA T. McQUADE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 31, 1985.

Attorney(s) appearing for the Case

Fred T. Witt, Jr., and David W. Elrod, for the petitioner.

Richard D. Ames and Mark L. Puryear, for the respondent.

OPINION

DAWSON, Chief Judge:

Petitioner's motion for summary judgment was assigned to Special Trial Judge Francis J. Cantrel for hearing, consideration, and ruling thereon.1 After a review of the record, we agree with and adopt his opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

CANTREL, Special Trial Judge:

This case is before...

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