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ZIRKER v. COMMISSIONER

Docket No. 16762-85.

87 T.C. 970 (1986)

LAURENCE R. AND MARGARET E. ZIRKER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 30, 1986.

Attorney(s) appearing for the Case

Rex C. Bush, for the petitioners.

James B. Ausenbaugh, for the respondent.

WHITAKER, Judge:

This case was assigned to and heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456 of the Code and Rules 180 and 181.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

PANUTHOS, Special Trial Judge:

Respondent determined the...

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