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FRIED v. COMMISSIONER

Docket Nos. 3533-83, 1454-85, 1455-85, 15390-85.

57 T.C.M. 1300 (1989)

T.C. Memo. 1989-430

Milton A. Fried, et al. v. Commissioner.

United States Tax Court.

Filed August 15, 1989.

Attorney(s) appearing for the Case

David Berman and Jan Neiman, for the petitioners. Bonnie Rosner, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.2 The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

Opinion of the Special Trial Judge

PANUTHOS, Special Trial Judge:

Respondent determined deficiencies in and additions to the Federal income...

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