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SCHWARTZ v. COMMISSIONER

Docket No. 15902-89.

63 T.C.M. 3062 (1992)

T.C. Memo. 1992-302

Sheldon Schwartz and Amy Schwartz v. Commissioner.

United States Tax Court.

Filed May 21, 1992.

Attorney(s) appearing for the Case

Mark S. Bauman, for the petitioners. Rose E. Gole, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:

This case is before the Court on petitioners' Motion for Leave to Move to Vacate Order of Dismissal and Decision Entered April 19, 1990. The facts, as alleged in the motion or as otherwise shown in the record, are as follows.

On April 7, 1989, respondent issued a notice of deficiency to petitioners for the taxable year 1981 in the amount of $69,251. The genesis of the deficiency is in respondent's disallowance...

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