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PUMPHREY v. COMMISSIONER

Docket No. 13538-94.

70 T.C.M. 882 (1995)

T.C. Memo. 1995-469

C. Merritt and Dorothy Pumphrey v. Commissioner.

United States Tax Court.

Filed October 3, 1995.

Attorney(s) appearing for the Case

Jay Fred Cohen, Baltimore, Md., for the petitioners. Alan R. Peregoy, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, 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

ARMEN, Special Trial Judge...

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