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HOFFENBERG v. COMMISSIONER

Docket No. 31549-87.

58 T.C.M. 1038 (1989)

T.C. Memo. 1989-676

Steven Hoffenberg v. Commissioner.

United States Tax Court.

Filed December 27, 1989.

Attorney(s) appearing for the Case

Shlomo Aaron Beilis, 360 Lexington Ave., New York, N.Y., for the petitioner. Terry W. Vincent and Andrew J. Mandell, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel pursuant to the provisions of section 7443A(b)(4)1 and Rule 180 et seq., Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of The Special Trial Judge

CANTREL, Special Trial, Judge:

This...

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