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McRAE v. COMMISSIONER

Docket No. 17147-82.

55 T.C.M. 1560 (1988)

T.C. Memo. 1988-374

Robert M. McRae and Barbara McRae v. Commissioner.

United States Tax Court.

Filed August 15, 1988.

Attorney(s) appearing for the Case

Roy B. Moore, 505 E. 200 South, Salt Lake City, Utah, for Robert M. McRae. John C. Green, for Barbara McRae. Steven M. Roth, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

This case was assigned for trial or other disposition to Special Trial Judge Helen A. Buckley pursuant to section 7456(d) (now designated section 7443A(b) of the Internal Revenue Code of 1986) and Rules 180 and 181.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

BUCKLEY...

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