OPINION GOFFE, Judge: These consolidated cases were assigned to Special Trial Judge Marvin F. Peterson pursuant to section 7456(d) 2 (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556 , 100 Stat. 2755 ), and Rules 180, 181, and 183.<fo…
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