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BLANCHARD v. COMMISSIONER

Docket No. 19762-83.

61 T.C.M. 1621 (1991)

T.C. Memo. 1991-1

John E. Blanchard v. Commissioner.

United States Tax Court.

Filed January 7, 1991.

Attorney(s) appearing for the Case

Joyce L. Sugawara, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Dinan pursuant to section 7443A(b) and Rules 180, 181, and 183.1 The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

DINAN, Special Trial Judge:

This case is before the Court on respondent's motion for summary judgment under Rule 121.

Respondent determined a deficiency...

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