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KOZLOWSKI v. COMMISSIONER

Docket No. 31144-86.

66 T.C.M. 754 (1993)

T.C. Memo. 1993-430

Jerome E. Kozlowski and Martha E. Kozlowski v. Commissioner.

United States Tax Court.

Filed September 15, 1993.

Attorney(s) appearing for the Case

Francis Burton Doyle, 375 W. Santa Clara St., San Jose, Calif., for the petitioners. Lamont R. Olson, for the respondent.

Memorandum Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell 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

POWELL, Special Trial Judge:

By notice of deficiency dated April 29, 1986, respondent determined a deficiency in...

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