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WIGGINS v. COMMISSIONER

Docket No. 14077-88.

92 T.C. 869 (1989)

HORACE LYNN WIGGINS AND JIMMIE SUE WIGGINS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 19, 1989.

Attorney(s) appearing for the Case

Joseph Ineich, for the respondent.

OPINION

NIMS, Chief Judge:

This case was assigned to Special Trial Judge Norman H. Wolfe pursuant to the provisions of section 7443A(b) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

WOLFE, Special Trial Judge:

Respondent determined a deficiency...

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