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INDUNI v. COMMISSIONER

Docket No. 8013-90.

98 T.C. 618 (1992)

NOEL D. INDUNI AND JANET E. INDUNI, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 20, 1992.

Attorney(s) appearing for the Case

Jon R. Eggleston, for petitioners.

Cheryl A. McInroy, for respondent.

OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

CANTREL, Special Trial Judge:

By statutory notice of deficiency dated February 5, 1990, respondent determined...

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