Memorandum Findings of Fact and Opinion
GOFFE, Judge:
This case was assigned to and heard by Special Trial Judge Joan Seitz Pate pursuant to section 7456(d) [redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755], and Rules 180, 181, and 183.
Opinion of the Special Trial Judge...
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