MEMORANDUM OPINION
DAWSON, Judge:
This case was heard by Special Trial Judge Lewis R. Carluzzo pursuant to section 7443A(b)(4) of the Internal Revenue Code of 1986, as amended, in effect at the time the petition was filed in this case, and Rules 180, 181, and 183 of the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, subsequent section references are to the Internal Revenue Code, as amended, in effect for 1993. The Court agrees with...
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