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CORRA RESOURCES, LTD. v. COMMISSIONER

Docket No. 467-85.

59 T.C.M. 102 (1990)

T.C. Memo. 1990-133

Corra Resources, Ltd. v. Commissioner.

United States Tax Court.

Filed March 14, 1990.

Attorney(s) appearing for the Case

Arthur H. Boelter and John J. White, Jr., for the petitioner. Anne M. DiFonzo and John E. White, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Stanley J. Goldberg pursuant to section 7443A(b)(4) of the Internal Revenue Code of 1986 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

GOLDBERG, Special Trial Judge:

Respondent determined the following...

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