Spencer M. and Suzanne J. Stillman - Page 1

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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.           
               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  
                            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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