Robert D. Grossman, Jr. - Page 1

                                 T.C. Memo. 1997-451                                  


                               UNITED STATES TAX COURT                                


                       ROBERT D. GROSSMAN, JR., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     

               Docket Nos.  20526-90, 14364-91.      Filed October 1, 1997.           

                    Petitioner (P) claims that two of the concessions                 
               that the Commissioner made in P's wife's (W's) dockets                 
               are applicable to P's dockets for purposes of the Rule                 
               155 computations in his dockets.                                       
                    Held:  The concessions that the Commissioner made                 
               in W's dockets are not applicable to P's dockets.                      

               Robert D. Grossman, Jr., pro se.                                       
               Stephen L. Braga, Eric F. Horvitz, and Miriam L. Fisher,1              

          *    This opinion supplements our previously filed Memorandum               
          Findings of Fact and Opinion in Grossman v. Commissioner, T.C.              
          Memo. 1996-452, filed Oct. 7, 1996.                                         
               1    Miriam L. Fisher was given leave to withdraw as counsel           
          in these dockets after petitioner’s first memorandum of law was             
          filed and did not have any responsibility for petitioner’s final            
                                                             (continued...)           




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