Irv C. Jaffe - Page 17




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          through their tenancy by the entirety ownership status, had equal           
          control over the dividends earned by the Vanguard Account.                  
               Accordingly, one-half of the $11,497.31 in dividend income             
          credited to the Vanguard Account from January 1, 1994, through              
          August 31, 1994, is includable in the gross income of Mr. Jaffe             
          for 1994, and, likewise, one-half of such dividend income is                
          includable in the gross income of Ms. Jaffe for 1994.                       




                                                 Decisions will be entered           
                                             under Rule 155.                          




























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