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CARLAND, INC. v. COMMISSIONER

Docket No. 18745-82.

90 T.C. 505 (1988)

CARLAND, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 30, 1988.

Attorney(s) appearing for the Case

J. Glenn Hahn, David E. Bass, David N. Zimmerman, and George D. Halper, for the petitioner.

James F. Kidd and James Cannon, for the respondent.

OPINION

DRENNEN, Judge:

This case was assigned for trial or other disposition to Special Trial Judge James M. Gussis pursuant to section 7456(d) (redesignated section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.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

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