T.C. Memo. 1996-546
UNITED STATES TAX COURT
STANLEY AND JEAN COHEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3956-93. Filed December 18, 1996.
Bernard S. Mark and Richard S. Kestenbaum, for petitioners.
Halvor N. Adams III, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge: Respondent determined deficiencies in, and
additions to, petitioners' Federal income taxes as follows:1
1Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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