T.C. Memo. 1996-274
UNITED STATES TAX COURT
LEO AND PAULINE GOLDMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 4838-94, 4839-94. Filed June 12, 1996.
Norman Nadel, for petitioners.
Pamela L. Cohen, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: These cases were heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182. All section
references are to the Internal Revenue Code for the taxable years
in issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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