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PREBLE v. COMMISSIONER

Docket No. 15066-87.

57 T.C.M. 295 (1989)

T.C. Memo. 1989-208

Wallace and Elizabeth Preble v. Commissioner.

United States Tax Court.

Filed May 1, 1989.

Attorney(s) appearing for the Case

Kevin O'Connell, 121 S.W. Morrison, Portland, Ore., for the petitioners. Marsha Keyes and Kathey I. Shaw, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge.

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.1 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.

This case is before the Court on cross-motions for summary judgment....

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