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1983 WESTERN RESERVE OIL & GAS CO., LTD. v. COMMISSIONER

Docket Nos. 17301-87, 17441-87, 17703-87, 18039-87, 18596-87, 18853-87, 27014-87.

95 T.C. 51 (1990)

1983 WESTERN RESERVE OIL & GAS CO., LTD., RICHARD G. SHAFFER, RECEIVER PENDENTE LITE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 12, 1990.

Attorney(s) appearing for the Case

Michael Christianson, for the petitioners in docket Nos. 17441-87, 17703-87, 18596-87, 18853-87, and 27014-87.

Charles Slyngstad, for the petitioner in docket Nos. 17301-87 and 18039-87.

Marsha Keyes, William Quealy, and Henry Schneiderman, for the respondent.

OPINION

NIMS, Chief Judge:

These cases were assigned to and heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A and Rule 180. All section references are to the Internal Revenue Code, unless otherwise stated, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

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