Memorandum Findings of Fact and Opinion
BUCKLEY, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) (redesignated sec. 7443A(b) by sec. 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rules 180, 181 and 182.
Findings of Fact
Petitioner Elizabeth W. Johnston, also known as Elizabeth Johns,
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