Memorandum Opinion
FAY, Judge:
This case was heard by Special Trial Judge Lee M. Galloway pursuant to the provisions of section 7443A and Rules 180, 181, and 183. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.
Opinion of the Special Trial...
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