T.C. Memo. 1997-576
UNITED STATES TAX COURT
THE MANCHESTER GROUP AND SUBSIDIARIES, FORMERLY TORREY
ENTERPRISES, INC., AND SUBSIDIARIES, FORMERLY TORREY DEVELOPMENT
CORPORATION AND SUBSIDIARIES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20509-92. Filed December 31, 1997.
J. Clancy Wilson, for petitioners.
William H. Quealy, Jr., and Alice M. Harbutte, for
respondent.
MEMORANDUM 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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