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SHARER v. COMMISSIONER

Docket Nos. 22562-92, 13219-93.

71 T.C.M. 2266 (1996)

T.C. Memo. 1996-91

Mary Lee Sharer v. Commissioner.

United States Tax Court.

Filed February 29, 1996.

Attorney(s) appearing for the Case

Roderick L. MacKenzie, Sacramento, Calif., for the petitioner. Kathryn K. Vetter, for the respondent.

MEMORANDUM OPINION

PARR, Judge:

These cases were assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The Court agrees with, and adopts, the Opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

COUVILLION, Special Trial Judge:

These cases are before the Court on petitioner's motions for award of litigation...

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