Parviz Lavi and Madeline Lavi - Page 1

                                 T.C. Memo. 1998-103                                  

                               UNITED STATES TAX COURT                                

                   PARVIZ LAVI and MADELINE LAVI, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8023-86.                    Filed March 16, 1998.           

               Gary S. Weinick, for petitioners.                                      
               Peggy Gartenbaum and Patricia A. Riegger, for respondent.              

                                 MEMORANDUM OPINION                                   

               SWIFT, Judge:  This matter is before us under Rule 1551 on             
          the parties’ disputed computations of the decision to be entered            
          herein to reflect properly a settlement agreement the parties               

          1    Unless otherwise indicated, all Rule references are to the             
          Tax Court Rules of Practice and Procedure, and all section                  
          references are to the Internal Revenue Code in effect for the               
          years at issue.                                                             

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