T.C. Memo. 1996-211
UNITED STATES TAX COURT
HARRIS LEVIN AND GAYLE LEVIN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 43572-85. Filed May 1, 1996.
Bruce I. Hochman and Martin N. Gelfand, for petitioners.
Mark Bernsley, for petitioner Gayle Levin.
Jason M. Silver, for respondent.
MEMORANDUM OPINION
COHEN, Judge: This case is now before the Court as a result
of the motion of petitioner Gayle Levin (Ms. Levin) for leave to
file out of time a motion to vacate a stipulated decision entered
August 10, 1989. Ms. Levin contends that her former husband,
petitioner Harris Levin (Mr. Levin), conducted this proceeding
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