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DeMARCO v. COMMISSIONER

Docket Nos. 37867-86, 39868-86.

55 T.C.M. 443 (1988)

T.C. Memo. 1988-124

Ronald J. DeMarco v. Commissioner. Linda K. DeMarco v. Commissioner.

United States Tax Court.

Filed March 22, 1988.

Attorney(s) appearing for the Case

Clyde D. Evans, Jr., 8228 Mayfield Rd., Chesterland, Ohio, for petitioner Ronald J. DeMarco. William F. Steiner, for petitioner Linda K. DeMarco. Richard S. Bloom, for the respondent.

Memorandum Findings of Fact and Opinion

GALLOWAY, Special Trial Judge:

These cases were assigned pursuant to the provisions of section 7456(d) of the Internal Revenue Code (redesignated section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755), and Rules 180, 181, and 182.1

These cases were consolidated for trial, briefing and opinion. Respondent...

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