United States Tax Court April 6, 1987, Docket No. 28713-83 (Loda Poultry Co. v. Commissioner)

lead-opinion

OPINION

DRENNEN, Judge-.

This case was assigned to and heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456(d)1 (redesignated as section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.2 After review of the record, we agree with and adopt his opinion which is set forth below.