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PIETANZA v. COMMISSIONER

Docket No. 29531-87.

92 T.C. 729 (1989)

PETER AND MARY PIETANZA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 30, 1989.

Attorney(s) appearing for the Case

Michael D. Savage, for the petitioners.

Richard D. Goldman, for the respondent.

OPINION

COHEN, Judge:

This case was assigned to Special Trial Judge Buckley pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rules 180 and 181.1 After a review of the record, we agree with and adopt her opinion which is set forth below.

FINDINGS OF FACT AND OPINION OF THE SPECIAL TRIAL JUDGE

BUCKLEY, Special Trial Judge:

This case is before us on cross...

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