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BURWELL v. COMMISSIONER

Docket Nos. 22943-83, 9585-84.

89 T.C. 580 (1987)

DAVID C. AND BETTY B. BURWELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT JAMES L. HARROLD, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 16, 1987.

Attorney(s) appearing for the Case

Darrell V. Rippy and Leda G. Williams, for the petitioners in docket No. 22943-83.

Darrell V. Rippy, Leda G. Williams, and William L. Manuel, for the petitioner in docket No. 9585-84.

Elaine T. Fuller, for the respondent.

OPINION

FEATHERSTON, Judge:

These consolidated cases were assigned to Special Trial Judge Helen A. Buckley pursuant to the provisions of section 7456(d) (redesignated sec. 7443A(b) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180 and 181.1 The Court agrees with and adopts her opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

BUCKLEY, Special...

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