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WISDOM v. COMMISSIONER

Docket No. 28112-88.

62 T.C.M. 164 (1991)

T.C. Memo. 1991-327

Robert Wisdom and Sandra Rattley v. Commissioner.

United States Tax Court.

Filed July 16, 1991.

Attorney(s) appearing for the Case

Larry Klayman, for the petitioners. Ruud L. Duvall, for the respondent.

Memorandum Findings of Fact and Opinion

DAWSON, Judge:

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

Opinion of the Special Trial Judge

PANUTHOS, Special Trial Judge:

This case is before the Court on respondent...

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