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BACKSTROM v. COMMISSIONER

Docket No. 5904-88.

73 T.C.M. 2723 (1997)

T.C. Memo. 1997-211

Sharon E. Backstrom, Harold J. and Zelma G. Barbret, Virginia Boland, John A. and Theresa A. Cislaghi, Estate of Roger W. Dornbrock, Deceased, Maryn J. Dornbrock, Personal Representative, Maryn J. Dornbrock, Gary E. and Beverly G. Engel, Hermann K. and Helen W. Enzmann, Don and Mary Everett, Kenneth B. and Mary J. Faust, Estate of Harold E. Frazer, Deceased, Elizabeth Frazer, Personal Representative, Charlotte V. Frazer, William M. and Martha J. Goodman, Paul W. and Kathleen M. Hammer, John and Rita C. Harvey, William R. and Ethel Kelley, Edward and Arles Kogelman, Terrence L. LaBadie, Frances Eng Lee, George R. Martell, Craig A. and Cynthia M. Peltier, Myra Joan Rodgers, William H. and Shirley M. Shaw, Karl L. and Sui Ti A. Siebert, John M. and Sandra Soper, Paul J. and Nancy L. Spindler, Gerard W.J. and Madeline Tremblay, Richard R. and Monica J. Riddle, Carol T. Jakubowski, and Arthur Miller v. Commissioner.

United States Tax Court.

Filed May 6, 1997.

Attorney(s) appearing for the Case

Andrew W. Mychalowych, for the petitioners Maryn J. Dornbrock and the Estate of Roger W. Dornbrock, Deceased. Karen J. Goheen, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

COUVILLION, Special Trial Judge:

Petitioner Maryn J. Dornbrock (Mrs. Dornbrock) has before the Court a motion...

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