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Z-TRON COMPUTER RESEARCH & DEVELOPMENT PROGRAM v. COMMISSIONER

Docket Nos. 23092-87, 23102-87.

91 T.C. 258 (1988)

Z-TRON COMPUTER RESEARCH & DEVELOPMENT PROGRAM, BRUCE R. AND ANGIE STIVERS, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Z-TRON COMPUTER RESEARCH & DEVELOPMENT PROGRAM # 2 LIMITED, BRUCE R. AND ANGIE STIVERS, PARTNERS OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 17, 1988.

Attorney(s) appearing for the Case

E. John Eagleton and Thomas G. Potts, for the petitioners.

Carolyn S. Rose, for the respondent.

OPINION

WHITAKER, Judge:

These cases were assigned to Special Trial Judge James M. Gussis pursuant to section 7443A(b)(4)1 and Rule 180 et seq., Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

GUSSIS, Special Trial Judge:

These cases are before the Court on petitioners...

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