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ERHARD v. COMMISSIONER

Docket Nos. 39473-85, 46712-86, 39532-87, 137-88.

62 T.C.M. 1 (1991)

T.C. Memo. 1991-290

Werner H. Erhard and Ellen V. Erhard v. Commissioner.

United States Tax Court.

Filed July 1, 1991.

Attorney(s) appearing for the Case

Michael I. Saltzman, Barbara T. Kaplan, and Robert F. Hermann, 45 Rockefeller Plaza, New York, N.Y., for the petitioner. Carmen M. Baerga, Craig Connell, Mildred M. Moon, and Raymond A. Kahn, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

These consolidated cases were assigned for trial or other disposition to Special Trial Judge James M. Gussis pursuant to section 7443A(b) of the Internal Revenue Code and Rule 180 et seq.1 This Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.

Opinion of the Special Trial Judge

GUSSIS, Special Trial Judge:

...

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