Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was heard pursuant to the provisions of section 7456(d) (redesignated section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.
This case is before the Court on respondent's Motion For Partial Summary Judgment filed September 13, 1985, together with a supporting memorandum of law, affidavit, and exhibits...
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