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CHERTKOF v. COMMISSIONER

Docket No. 2345-75.

66 T.C. 496 (1976)

JACK O. CHERTKOF AND SOPHIE CHERTKOF, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 21, 1976.

Attorney(s) appearing for the Case

Edward S. Smith and Lawrence M. Katz, for the petitioners.

Robert B. Perry, for the respondent.

DAWSON, Chief Judge:

This motion for summary judgment was assigned to and heard by Special Trial Judge Randolph F. Caldwell, Jr. The Court agrees with and adopts his opinion which is set out below.1

OPINION OF THE SPECIAL TRIAL JUDGE

CALDWELL, Special Trial Judge:

Respondent determined a deficiency in the income tax of Jack O. and Sophie Chertkof (hereinafter referred to as petitioners) for the calendar...

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