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BEATTY v. COMMISSIONER

Docket No. 8273-94.

106 T.C. 268 (1996)

JOHN D. AND KAREN BEATTY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 17, 1996.

Attorney(s) appearing for the Case

Stephen E. Arthur and Ronald M. Soskin, for petitioners.

Ronald T. Jordan, for respondent.

DAWSON, Judge:

This case was assigned to Special Trial Judge Lewis R. Carluzzo pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

CARLUZZO, Special Trial Judge:

Respondent determined a deficiency in petitioners' 1991 Federal income tax in the...

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