OPINION
KÖRNER, Judge:
This case was assigned to Special Trial Judge Helen A. Buckley pursuant to the provisions of section 7456(d)(3) of the Code (redesignated sec. 7443A(b)(3) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180, 181, and 182.
OPINION OF THE SPECIAL TRIAL JUDGE
BUCKLEY,...
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