T.C. Memo. 1995-523
UNITED STATES TAX COURT
ESTATE OF MARK R. WOODWARD, DECEASED, LILLIAN H. WOODWARD,
EXECUTRIX, AND LILLIAN H. WOODWARD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10137-88. Filed November 6, 1995.
Victor F. Keen, for petitioners.
John Aletta, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
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