SUPPLEMENTAL MEMORANDUM OPINION*
ARMEN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
This case involves deficiencies in income taxes and additions to tax for the taxable years 1978 through 1982. It has been the subject of three prior Opinions of this Court, namely, Brown v. Commissioner [Dec. 45,516...
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