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PIETROMONACO v. COMMISSIONER

Docket No. 6870-89.

62 T.C.M. 827 (1991)

T.C. Memo. 1991-472

Erminio E. Pietromonaco and Emilia R. Pietromonaco v. Commissioner.

United States Tax Court.

Filed September 25, 1991.

Attorney(s) appearing for the Case

Bruce I. Hochman, 9100 Wilshire Blvd., Beverly Hills, Calif., for the petitioner. Mary Schewatz, for the respondent.

Supplemental Memorandum Opinion

PARR, Judge:

On August 5, 1991, we filed our opinion in this case, Pietromonaco v. Commissioner [Dec. 47,518(M)], T.C. Memo. 1991-361 (Pietromonaco I). Petitioners filed a Rule 161, motion for reconsideration of findings or opinion.

In Pietromonaco I, we held that petitioner-wife failed to satisfy all of the requirements of section 6013(e) and was liable for...

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