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MODERN COMPUTER GAMES, INC. v. COMMISSIONER

Docket No. 1866-89.

96 T.C. 839 (1991)

MODERN COMPUTER GAMES, INC., CARL D. RADER, TAX MATTERS PERSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 20, 1991.

Attorney(s) appearing for the Case

Kirk A. McCarville, for the petitioner.

Christine V. Olsen, for the respondent.

OPINION

NIMS, Chief Judge:

This case was assigned to Special Trial Judge Buckley pursuant to the provisions of section 7443A(b).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

BUCKLEY, Special Trial Judge:

This matter is before us on petitioner's motion for summary...

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