BUFFINGTON v. COMMISSIONER

Memorandum Findings of Fact and Opinion

NIMS, Chief Judge:

This case was assigned to Special Trial Judge John J. Pajak pursuant to section 7443A(b) of the Code and Rules 180, 181 and 183. The Court agrees with and adopts his opinion which is set forth below.

PAJAK, Special Trial Judge:

Respondent determined deficiencies in petitioner Robert R. Buffington's Federal income taxes and additions to taxes as follows:

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