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SWEDELSON v. COMMISSIONER

Docket No. 14551-89.

61 T.C.M. 1650 (1991)

T.C. Memo. 1991-10

Michael L. and Katheline M. Swedelson v. Commissioner.

United States Tax Court.

Filed January 14, 1991.

Attorney(s) appearing for the Case

Gary R. Bennett, 39210 State St., Fremont, Calif., for the petitioners. James P. Thurston, for the respondent.

Memorandum Opinion

DAWSON, Judge:

These cases were assigned to Special Trial Judge Norman H. Wolfe pursuant to the provisions of section 7456 (redesignated as section 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) 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

WOLFE...

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