Leo and Pauline Goldman - Page 1

                                       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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