COHEN v. COMMISSIONER

Docket No. 33166-87.

57 T.C.M. 804 (1989)

T.C. Memo. 1989-311

Robert M. and Hannah Cohen v. Commissioner.

United States Tax Court.

Filed June 26, 1989.


Attorney(s) appearing for the Case

Stephen E. Sokolic and John E. Kaskey, 1700 Market St., Philadelphia, Pa., for the petitioners. Paul J. Sude and Daniel Morman, for the respondent.


Memorandum Opinion

WHALEN, Judge:

This case was assigned to Special Trial Judge John J. Pajak pursuant to section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code and all rule numbers refer to the Tax Court Rules of Practice and Procedure.) The Court agrees with and adopts his opinion which is set forth below.

Opinion of the Special Trial Judge

PAJAK, Special Trial Judge:

Respondent determined...

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