SUPPLEMENTAL MEMORANDUM OPINION
DAWSON, Judge:
This case was assigned to Special Trial Judge Norman H. Wolfe pursuant to Rules 180, 181, and 183. All Rule references are to the Tax Court Rules of Practice and Procedure. All section references are to the Internal Revenue Code in effect at the time the petition was filed, unless otherwise indicated. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
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