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MOO HYUNG v. COMMISSIONER

Docket No. 27826-90.

63 T.C.M. 1708 (1992)

T.C. Memo. 1992-5

Moo Hyung and Si Hong Cho v. Commissioner.

United States Tax Court.

Filed January 2, 1992.

Attorney(s) appearing for the Case

John M. Kirwan, 3250 Wilshire Blvd., Los Angeles, Calif., for the petitioners. Thomas R. Lamons, for the respondent.

Memorandum Opinion

DAWSON, Judge:

This case was assigned to Special Trial Judge Larry L. Nameroff 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

NAMEROFF, Special Trial Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction...

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