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KIRSCHENBAUM v. COMMISSIONER

Docket No. 10133-00.

81 T.C.M. 1554 (2001)

T.C. Memo. 2001-102

Irvin Kirschenbaum v. Commissioner.

United States Tax Court.

Filed April 26, 2001.

Attorney(s) appearing for the Case

Marc C. Rosenberg, for the petitioner.

Jack H. Klinghoffer, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge:

This case was assigned to Special Trial Judge Stanley J. Goldberg, pursuant to Rules 180, 181, and 183. Unless otherwise indicated, section references are to the Internal Revenue Code, and Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

GOLDBERG, Special...

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