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CROWELL v. COMMISSIONER

Docket No. 364-93.

102 T.C. 683 (1994)

DONALD V. CROWELL AND JOANNE CURRIE-CROWELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 28, 1994.

Attorney(s) appearing for the Case

Donald V. Crowell and Joanne Currie-Crowell, pro sese.

Steven M. Roth and David A. Winsten, for respondent.

OPINION

DAWSON, Judge:

This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 This Court agrees with and adopts the opinion of the Chief Special Trial Judge which is set forth below.

OPINION OF THE CHIEF SPECIAL TRIAL JUDGE

PANUTHOS, Chief Special Trial Judge:

This matter...

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