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BERENSON v. COMMISSIONER

Docket Nos. 3677-70, 6069-70, 6088-70, 6116-70, 2920-71, 3870-71.

37 T.C.M. 415 (1978)

T.C. Memo. 1978-89

Louis Berenson and Sue A. Berenson et al. v. Commissioner.

United States Tax Court.

Filed March 6, 1978.

Attorney(s) appearing for the Case

Isidore Feldman, for the petitioners. Marwin A. Batt and Bernard S. Mark, for the respondent.

Supplemental Memorandum Opinion

QUEALY, Judge:

This proceeding arises out of the remand of this Court's opinion (59 T.C. 412 (1972)) by the United States Court of Appeals for the Second Circuit. Berenson v. Commissioner [74-2 USTC ¶ 9806], 507 F.2d 262 (2d Cir. 1974).

The petitioners owned all of the stock of Kitro Casuals, Inc., and Marilyn Togs, Inc., both New York corporations...

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