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T.C. Memo. 1995-591
UNITED STATES TAX COURT
SPENCER M. STILLMAN AND SUZANNE J. STILLMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 39448-85. Filed December 13, 1995.
Steve Mather and Elliott H. Kajan, for petitioner Suzanne J.
Stillman.
William E. Crockett, for petitioner Spencer M. Stillman.
Jack Klinghoffer, for respondent.1
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial Judge Larry L.
Nameroff pursuant to section 7443A(b)2 and Rule 180-182. The Court agrees
with and adopts the opinion of the Special Trial Judge, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
NAMEROFF, Special Trial Judge: This case is before us on
1 Frederic J. Adam was specially recognized as attorney for the law
firm of Hochman, Salkin & DeRoy in connection with the subpoenaed testimony of
one of its employees.
2 All section references are to the Internal Revenue Code in effect
for the year at issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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