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LOFTUS v. COMMISSIONER

Docket Nos. 12440-85R-12444-85R.

90 T.C. 845 (1988)

DENNIS LOFTUS, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, AND JOHN HOH, KENNETH CARROLL, ANTHONY GRAU, AND ANGELO FERRARO, FORMER TRUSTEES OF THE BREWERY WORKERS PENSION FUND, RESPONDENTS

United States Tax Court.

Filed May 9, 1988.

Attorney(s) appearing for the Case

Robert Whoriskey and Lawrence V. Kelly, for the petitioners.

Sarah Hall and Daniel Wiles, for the respondent Commissioner.

Susan Martin and Jacob Friedman, for the respondent former trustees.

OPINION

NIMS, Judge:

These cases were heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456 of the Code.2 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

PANUTHOS, Special Trial Judge:

Petitioners, in these consolidated cases, brought actions for declaratory judgment under...

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