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WHITE v. COMMISSIONER

Docket No. 4394-89.

60 T.C.M. 958 (1990)

T.C. Memo. 1990-528

Theodore White v. Commissioner.

United States Tax Court.

Filed October 9, 1990.

Attorney(s) appearing for the Case

Howard Lisch, 305 Broadway, New York, N.Y., for the petitioner. Howard Rosenblatt, for the respondent.

Memorandum Opinion

DAWSON, 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:

In a notice of deficiency dated January 21, 1987, respondent determined a deficiency...

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