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NERAD v. COMMISSIONER

Docket No. 13745-97.

78 T.C.M. 795 (1999)

T.C. Memo. 1999-376

Charles A. Nerad v. Commissioner.

United States Tax Court.

Filed November 12, 1999.

Attorney(s) appearing for the Case

Charles A. Nerad, pro se. Karen N. Sommers, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Stanley J. Goldberg, pursuant to Rules 180, 181, and 183.1 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:

On January 29, 1997, respondent issued a notice of final determination denying petitioner's claim to...

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