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ELLIS v. COMMISSIONER

Docket No. 43955-86.

55 T.C.M. 619 (1988)

T.C. Memo. 1988-161

Robert L. and Ilona B. Ellis v. Commissioner.

United States Tax Court.

Filed April 19, 1988.

Attorney(s) appearing for the Case

Robert L. and Ilona B. Ellis, pro se. Donald L. Wells, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

This case was assigned pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) of the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) of the Code1 and Rule 180 et seq. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

COUVILLION...

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