T.C. Memo. 1997-429
UNITED STATES TAX COURT
ARNOLD S. AND ELLEN K. JACOBS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1333-89. Filed September 23, 1997.
Abraham Gutwein and Ira Akselrad, for petitioners.
Louis A. Ramunno and Paulette Segal, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of section
7443A(b)(4) and Rules 180, 181, and 183. All section references
are to the Internal Revenue Code in effect for the tax year in
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