Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
This case was assigned to and heard by Special Trial Judge Joan Seitz Pate pursuant to section 7456(c) and (d) of the Internal Revenue Code of 1954, as amended, General Order No. 8 (81 T. C. XXIII) (1983) and Rules 180 and 181, Tax Court Rules of Practice and Procedure.
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