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COURSON v. COMMISSIONER

Docket No. 8904-88.

59 T.C.M. 429 (1990)

T.C. Memo. 1990-196

Thomas G. and Sandra J. Courson v. Commissioner.

United States Tax Court.

Filed April 17, 1990.

Attorney(s) appearing for the Case

James Michael O'Byrne, for the petitioners. Abbey B. Garber, for the respondent.

Memorandum Opinion

SCOTT, Judge:

This case was assigned to Special Trial Judge Helen A. Buckley pursuant to section 7443A(b) of the Code 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

BUCKLEY, Special Trial Judge:

Respondent determined deficiencies in petitioners' joint Federal income tax as follows...

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