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PERKINS v. COMMISSIONER

Docket No. 14968-87.

92 T.C. 749 (1989)

JAMES W. PERKINS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 3, 1989.

Attorney(s) appearing for the Case

Kevin O'Connell, for the petitioner.

Marsha Keyes and Kathey I. Shaw, for the respondent.

OPINION

GERBER, Judge:

This case was assigned to Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986 and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL...

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