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LEBOWITZ v. COMMISSIONER

Docket No. 27543-82.

62 T.C.M. 249 (1991)

T.C. Memo. 1991-344

S. Peter Lebowitz and Theresa Lebowitz v. Commissioner.

United States Tax Court.

Filed July 29, 1991.

Attorney(s) appearing for the Case

Thomas S. Carles, 570 W. Mount Pleasant Ave., Livingston, N.J., Alan Scott Laufer and John L. Pritchard, for the petitioners. Ismael Gonzales, for the respondent.

Memorandum Opinion

COHEN, Judge:

This case is before the Court on remand from the Court of the Appeals for the Second Circuit in Lebowitz v. Commissioner [90-2 USTC ¶ 50,564], 917 F.2d 1314, 1319 (2d Cir. 1990), revg. and remanding our prior opinion [Dec. 45,630(M)], T.C. Memo. 1989-178.

Petitioners were limited partners in a partnership (Fenwick) formed in 1976 to...

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