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October 1, 1977, to March 31, 1978

Volume 69

(Cite 69 T.C.)

MARY T. PITTMAN

REPORTER OF DECISIONS

U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON: 1978

For sale by the Superintendent of Documents. U.S. Government Printing Office

Washington, D.C. 20402
Stock Number 028-005-00137-3

JUDGES OF THE UNITED STATES TAX COURT

Chief Judge
C. MOXLEY FEATHERSTON

ARNOLD RAUM
WILLIAM M. DRENNEN
IRENE F. SCOTT
WILLIAM M. FAY
HOWARD A. DAWSON, JR.
THEODORE TANNENWALD, JR.
CHARLES R. SIMPSON
LEO H. IRWIN

Judges

SAMUEL B. STERRETT
WILLIAM H. QUEALY
WILLIAM A. GOFFE
CYNTHIA HOLCOMB HALL
DARRELL D. WILES
RICHARD C. WILBUR

(Vacancy)

Retired judges recalled to perform judicial duties under the provisions of section 7447 of the Internal Revenue Code of 1954:

BRUCE M. FORRESTER

J. GREGORY BRUCE
NORMAN O. TIETJENS

Special Trial Judges JAMES M. GUSSIS

MURRAY H. FALK CHARLES R. JOHNSTON

EDNA G. PARKER RANDOLPH F. CALDWELL, JR. FRED S. GILBERT, JR. LEHMAN C. AARONS

FRANCIS J. CANTREL"

CHARLES S. Casazza, Clerk

1 Appointed December 21, 1977.

IN MEMORIAM

EDWARD C. RADUE

SPECIAL ASSISTANT TO THE CHIEF JUDGE

Special Session United States Tax Court

Washington, D.C. October 28, 1977.
CHIEF JUDGE C. MOXLEY FEATHERSTON PRESIDING

THE CLERK: The United States Tax Court is convened in special session this afternoon for the purpose of conducting a memorial service for the late Edward C. Radue, who was Special Assistant to the Chief Judge. Chief Judge Featherston is presiding.

CHIEF JUDGE FEATHERSTON: We are gathered today to pay tribute and respect to Edward C. Radue who worked for the Tax Court from 1937 to 1972, a period of thirty-five years. During most of this period, he served as a Commissioner, a position we now refer to as a Special Trial Judge, and as Special Assistant to the Chief Judge.

Mr. Radue left a devoted family-his wife, Mrs. Josephine Radue; two daughters, Linda Lee Wilson and Joanne Burns; a son, Peter F. Radue; a brother, Fordham W. Radue; and four grandchildren, Catherine and Josephine Burns and Robert and Alexander Wilson. To his family, and I know I speak for the entire Court and for his great host of friends, we extend our deepest sympathy. We want you to know that we share, at least in a small measure, the grief of your loss, because Ed Radue was our friend. During the past week I have received letters from lawyers and former Tax Court employees from all over the United States, asking me to extend to you their condolences and their sympathies.

Ed Radue served as Special Assistant to five Chief Judges of this Court. Three of them are with me today on the bench: Judge Turner, Judge Tietjens, and Judge Drennen. He also served as

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