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CONGELLIERE v. COMMISSIONER

Docket Nos. 34413-84, 34499-85, 34853-85, 6432-86.

59 T.C.M. 709 (1990)

T.C. Memo. 1990-265

Ronald G. Congelliere, et al. v. Commissioner.

United States Tax Court.

Filed May 30, 1990.

Attorney(s) appearing for the Case

Ronald G. Congelliere and Mark S. McFarlane, pro se. Patrick McGinnis and Sheri Hinnant, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

These consolidated cases were assigned to Special Trial Judge Daniel J. Dinan pursuant to section 7443A(b) of the Internal Revenue Code of 1986 and Rules 180, 181, and 183.2 The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

DINAN, Special Trial Judge:

...

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