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DONOVAN v. COMMISSIONER

Docket Nos. 18855-97, 23139-97.

80 T.C.M. 78 (2000)

T.C. Memo. 2000-220

William M. Donovan v. Commissioner.

United States Tax Court.

Filed July 21, 2000.

Attorney(s) appearing for the Case

Alyce C. Halchak, for the petitioner. Julia A. Cannarozzi, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

These cases were assigned to Special Trial Judge Lewis R. Carluzzo pursuant to section 7443A(b)(4) and 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

CARLUZZO, Special Trial Judge:

On March 25, 1997, respondent issued a notice of final determination denying...

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