Memorandum Findings of Fact and Opinion
DAWSON, Judge:
This case was assigned to Special Trial Judge Helen A. Buckley pursuant to section 7443A(b)(4) 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
BUCKLEY, Special Trial Judge:
By statutory notice, respondent determined a deficiency in petitioners...
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