OPINION STERRETT, Chief Judge: This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556 , 100 Stat. 2755 ) and Rule 180 et seq. 1</footnotema…
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