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ESTATE OF BAXTER v. COMMISSIONER

Docket No. 28193-89.

63 T.C.M. 1706 (1992)

T.C. Memo. 1992-4

Estate of Carl L. Baxter, Deceased, Stephen C. Baxter, Personal Representative, and Paula Baxter v. Commissioner.

United States Tax Court.

Filed January 2, 1992.

Attorney(s) appearing for the Case

R. Dow Bonnell, 1518 S. Cheyenne, Tulsa, Okla., for the petitioners. Donald E. Edwards and Nancy S. Vozar, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4) 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

COUVILLION, Special Trial Judge:

Respondent issued a notice of deficiency in which he determined that petitioners...

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