CHARLTON v. COMMISSIONER

Docket No. 46689-86.

61 T.C.M. 3011 (1991)

T.C. Memo. 1991-285

Thomas E. and Judith C. Charlton v. Commissioner.

United States Tax Court.

Filed June 27, 1991.


Attorney(s) appearing for the Case

Larry Kars, 575 Lexington Ave., New York, N.Y., for the petitioners. Doreen M. Susi and Dennis C. DeBerry, for the respondent.


Supplemental Memorandum Opinion

DAWSON, Judge.

This matter is before the Court on petitioners' motion pursuant to Rule 162 to vacate or revise the decision entered herein on November 26, 1990. All section references are to the Internal Revenue Code as amended and in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Petitioners contend that the decision should be vacated or revised because...

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