Joseph Green and Fe Green - Page 1
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T.C. Memo. 1995-466
UNITED STATES TAX COURT
JOSEPH GREEN AND FE GREEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18985-94. Filed October 2, 1995.
Joseph Green, for petitioners.
Steven W. Ianacone, for respondent.
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443(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.
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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