T.C. Memo. 1999-410
UNITED STATES TAX COURT
ANTHONY AND ESTHER SICARI, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11761-95. Filed December 16, 1999.
Sheldon Eisenberger, Richard L. Herzfeld, and Cris Alcamo,
for petitioners.
Wendy Sands, Paul Darcy, and Theodore Leighton, for
respondent.
SUPPLEMENTAL MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Norman H. Wolfe pursuant to Rules 180, 181, and 183. All
Rule references are to the Tax Court Rules of Practice and
Procedure. All section references are to the Internal Revenue
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