T.C. Memo. 1995-582
UNITED STATES TAX COURT
LEON AND BELLE ATKIND, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20539-89. Filed December 6, 1995.
Neil L. Prupis, for petitioners.
Louise Forbes and William T. Hayes, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183.1 The Court agrees with
1
All section references are to the Internal Revenue Code, in
effect for the year in issue, unless otherwise indicated. All
Rule references are to the Tax Court Rules of Practice and
(continued...)
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