PROVIZER v. COMMISSIONER

Docket No. 27141-86.

63 T.C.M. 2531 (1992)

T.C. Memo. 1992-177

Harold M. Provizer and Joan Provizer v. Commissioner.

United States Tax Court.

Filed March 25, 1992.


Attorney(s) appearing for the Case

Bernard S. Mark, Richard S. Kestenbaum, and Deborah S. Hack, for the petitioners. Mary Hamilton and Michele J. Gormley, for the respondent.


Memorandum Findings of Fact and Opinion

FAY, Judge:

This case was assigned to Special Trial Judge Norman H. Wolfe pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.

Opinion of the Special Trial Judge

WOLFE, Special Trial Judge:

Respondent determined a deficiency of $17,724 in petitioners...

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