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ESPINOSA v. COMMISSIONER

Docket No. 8900-94.

107 T.C. 146 (1996)

GUILLERMO BAEZ ESPINOSA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 24, 1996.

Attorney(s) appearing for the Case

John P. Bender, for petitioner.

Joni D. Larson, for respondent.

DAWSON, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge that is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

POWELL, Special Trial Judge:

Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as...

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