concurring: I concur only because I am bound by the result in David J. Primuth, 54 T.C. 374. Otherwise, my heart and mind are with the dissent in Primuth.
Dbennen, Withey, Scott, and Hoyt, JJ., agree with this concurring opinion.concurring: I concur only because I am bound by the result in David J. Primuth, 54 T.C. 374. Otherwise, my heart and mind are with the dissent in Primuth.
Dbennen, Withey, Scott, and Hoyt, JJ., agree with this concurring opinion.