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OWENS v. COMMISSIONER

Docket Nos. 9412-79, 11711-80.

49 T.C.M. 1101 (1985)

T.C. Memo. 1985-156

Shelley J. Owens, aka Shelley J. Litwiller v. Commissioner. Shelley J. Owens and Bruce W. Owens v. Commissioner.

United States Tax Court.

Filed April 1, 1985.

Attorney(s) appearing for the Case

Karen Smith Bryan, 555 South Flower St., Los Angeles, Calif., for the petitioners. Charles W. Jeglikowski, for the respondent.

Supplemental Memorandum Opinion

FAY, Judge:

These consolidated cases are before the Court on respondent's motion under Rule 1611 for reconsideration of our earlier memorandum opinion, T.C. Memo. 1983-302, which was filed on May 26, 1983.

Petitioners, Shelley J. and Bruce W. Owens, resided in Palos Verdes Estates, Calif., when the petitions were filed herein. The relevant facts are...

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