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OCCEAN v. COMMISSIONER

Docket No. 29740-89.

62 T.C.M. 675 (1991)

T.C. Memo. 1991-439

Joseph Occean and Julia Occean v. Commissioner.

United States Tax Court.

Filed September 9, 1991.

Attorney(s) appearing for the Case

Larry Kars, 575 Lexington Ave., New York, N.Y., for the petitioners. William R. Davis, Jr., for the respondent.

Memorandum Opinion

DAWSON, Judge.

This case was assigned to Special Trial Judge John J. Pajak pursuant to the provisions of section 7443A(b) and Rule 180 et seq.1 The Court agrees with and adopts his opinion, which is set forth below.

Opinion of the Special Trial Judge

PAJAK, Special Trial Judge.

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction and petitioners...

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