T.C. Memo. 1996-45
UNITED STATES TAX COURT
KENT J. AND RUTH W. DAWSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25220-93. Filed February 12, 1996.
Kenneth A. Burns, for petitioners.
David W. Sorensen, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial Judge
Stanley J. Goldberg 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.
1 All section references are to the Internal Revenue Code in
effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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