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RUSSELL v. COMMISSIONER

Docket No. 5983-85.

53 T.C.M. 692 (1987)

T.C. Memo. 1987-216

Melissa J. Russell and Thomas C. Newman v. Commissioner.

United States Tax Court.

Filed April 29, 1987.

Attorney(s) appearing for the Case

Barry Becker, for the petitioners. Anne W. Durning, for the respondent.

Memorandum Opinion

DINAN, Special Trial Judge:

This case was heard pursuant to section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) of the Code and Rules 180, 181 and 182.1 For convenience and clarity, the findings of fact and conclusions of law have been combined in this opinion.

Respondent determined deficiencies in Melissa J. Russell's

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