concurring: I agree with the majority for the reasons set forth in my concurring opinion in David J. Primuth, 54 T.C. 374.
Dawson, J. agrees with this concurring opinion.concurring: I agree with the majority for the reasons set forth in my concurring opinion in David J. Primuth, 54 T.C. 374.
Dawson, J. agrees with this concurring opinion.