Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
These cases were assigned to Special Trial Judge Lee M. Galloway pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755), and Rules 180, 181, and 183 of the Tax Court Rules of Practice and Procedure.
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