OPINION
CHABOT, Judge:
This case was assigned to Special Trial Judge Pate pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180 and 181.
OPINION OF THE SPECIAL TRIAL JUDGE
PATE, Special Trial Judge:
This case is before...
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