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WUEBKER v. COMMISSIONER

Docket No. 11472-96.

110 T.C. 431 (1998)

FREDRICK J. AND RUTH WUEBKER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 23, 1998.

Attorney(s) appearing for the Case

Paul L. Wright, for petitioners.

Stephen J. Neubeck, for respondent.

GERBER, Judge:

This case was heard by Special Trial Judge Stanley J. Goldberg, pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

GOLDBERG, Special Trial Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for...

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