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FAN v. COMMISSIONER

Docket No. 17036-99.

117 T.C. 32 (2001)

117 T.C. No. 3

STEPHEN T. FAN AND LANDA C. FAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 24, 2001.

Attorney(s) appearing for the Case

Jon R. Vaught, for petitioners.

H. Clifton Bonney, Jr., for respondent.

OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Lewis R. Carluzzo pursuant to 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

CARLUZZO, Special Trial Judge:

Respondent determined deficiencies of $2,111 and $1,114 in petitioners' Federal...

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