T.C. Memo. 1998-94
UNITED STATES TAX COURT
HUGH AND LINDA JANOW, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17775-87. Filed March 4, 1998.
Hugh Janow, for petitioners.
Lawrence L. Davidow, for respondent.
MEMORANDUM OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge John J. Pajak, pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
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