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GENESIS OIL & GAS, LTD. v. COMMISSIONER

Docket No. 19685-87.

93 T.C. 562 (1989)

GENESIS OIL & GAS, LTD. G & W PETROLEUM CORPORATION, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 6, 1989.

Attorney(s) appearing for the Case

Martin L. Gelfand, for the petitioner.

Ronald M. Rosen, for the respondent.

OPINION

GERBER, Judge:

This case was assigned to Special Trial Judge Larry L. Nameroff pursuant to section 7443A(b) of the Code1 and Rule 180 et seq. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

NAMEROFF, Special Trial Judge:

Petitioner filed a petition with this Court on June 23, 1987, seeking a redetermination...

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