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NITZBERG v. COMMISSIONER

Docket Nos. 1327-73, 1360-73.

34 T.C.M. 996 (1975)

T.C. Memo. 1975-228

Irving Nitzberg and Ida Nitzberg v. Commissioner. Sid Miller and Helen Miller v. Commissioner.

United States Tax Court.

Filed July 14, 1975.

Attorney(s) appearing for the Case

Stephen J. Schwartz, 234 Front, San Francisco, Calif., and Charles A. Lane, for the petitioners. Edward B. Simpson, for the respondent.

Supplemental Memorandum Findings of Fact and Opinion

GOFFE, Judge:

Pursuant to Rule 161, Tax Court Rules of Practice and Procedure, both parties have requested by motion filed June 18, 1975, that this Court reconsider our prior memorandum opinion [CCH Dec. 33,216(M)] filed on May 21, 1975. The parties now agree that this case was submitted on a fully stipulated basis pursuant to Rule 122, Tax Court Rules of Practice and Procedure, with the understanding...

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