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MAILMAN v. COMMISSIONER

Docket No. 45238-86.

56 T.C.M. 1380 (1989)

T.C. Memo. 1989-88

Norton W. and Virginia A. Mailman v. Commissioner.

United States Tax Court.

Filed February 28, 1989.

Attorney(s) appearing for the Case

Richard S. Kestenbaum, 60 E. 42nd St., New York, N.Y., and Bernard S. Mark, for the petitioners. Victoria Wilson Fernandez and Rose E. Gole, for the respondent.

Memorandum Findings of Fact and Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986 and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

POWELL, Special Trial Judge:

Respondent determined...

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