T.C. Memo. 2003-305
UNITED STATES TAX COURT
MALCOLM I. LEWIN AND TRINA LEWIN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 477-95. Filed November 3, 2003.
Christopher S. Rizek, for petitioners.
Louise R. Forbes and D. Sean McMahon, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: This case was assigned to Special Trial
Judge Norman H. Wolfe pursuant to the provisions of section
7443A(b)(4) in effect when these proceedings commenced and Rules
180, 181, and 183. Unless otherwise indicated, section
references are to the Internal Revenue Code in effect at relevant
times, and Rule references are to the Tax Court Rules of Practice
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