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  5. 56 T.C.M. 669 (1988)
 

HOWARD v. COMMISSIONER

Docket Nos. 10115-85, 11681-85, 40555-86, 40556-86, 40557-86, 40559-86, 40560-86, 40561-86, 40562-86.

56 T.C.M. 669 (1988)

T.C. Memo. 1988-531

Howard S. and Anne F. Howard, et al. v. Commissioner.

United States Tax Court.

Filed November 15, 1988.

Attorney(s) appearing for the Case

Gary Alohawiwoole Altman, 400 Hualani St., Hilo, Hawaii, and Laurin W. Schutter, for the petitioners. Gregory A. Roth, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

These consolidated cases were assigned for trial or other disposition to Special Trial Judge James M. Gussis pursuant to section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) and Rules 180 et seq.2 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

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