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GRAY v. COMMISSIONER

Docket No. 27394-88.

59 T.C.M. 812 (1990)

T.C. Memo. 1990-282

Russell E. Gray, Jr. v. Commissioner.

United States Tax Court.

Filed June 6, 1990.

Attorney(s) appearing for the Case

Scott W. Stauffer, for the petitioner. Robert A. Varra, for the respondent.

Memorandum Opinion

FAY, Judge:

This case is assigned to Special Trial Judge Joan Seitz Pate pursuant to the provisions of section 7443A(b)(4) and Rule 180 et seq.1 After a review of the record, we agree with and adopt her opinion which is set forth below.

Opinion of the Special Trial Judge

PATE, Special Trial Judge:

This case is before the Court on cross motions to dismiss for lack of jurisdiction. Respondent...

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