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BAILEY v. COMMISSIONER

Docket Nos. 10193-78, 4505-82, 3781-85.

63 T.C.M. 2000 (1992)

T.C. Memo. 1992-72

Guy B. Bailey, Jr. and Lois M. Bailey, et al. v. Commissioner.

United States Tax Court.

Filed February 5, 1992.

Attorney(s) appearing for the Case

Peter L. Faber, Richard A. Levine, 30 Rockefeller Plaza, New York, N.Y., and Carlton M. Smith, for the petitioners. Gerald A. Thorpe, for the respondent.

Supplemental Memorandum Opinion

SCOTT, Judge:

These cases were reassigned to Special Trial Judge John J. Pajak, pursuant to the provisions of section 7443A(b)(4) and Rule 180, 181, and 183.2 The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

Opinion of the Special Trial Judge

PAJAK, Special Trial Judge:

The U.S. Court of Appeals for the Second Circuit in a divided...

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