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GIVENS v. COMMISSIONER

Docket No. 4951-85.

90 T.C. 1145 (1988)

DONALD AND JEAN GIVENS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 16, 1988.

Attorney(s) appearing for the Case

Debra Bowen, for the petitioner.

Joyce Sugawara, for the respondent.

OPINION

NIMS, Chief Judge:

This case1 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 section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180, 181, and 182.2 The Court agrees with and adopts her opinion which is set forth below.

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