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LOMBARDO v. COMMISSIONER

Docket Nos. 18009-81, 16224-82, 18017-82, 18448-82, 26377-82, 5803-88.

99 T.C. 342 (1992)

SALVADOR A. LOMBARDO, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 28, 1992.

Attorney(s) appearing for the Case

John Harrison Wegge, for petitioners in docket Nos. 18009-81, 18448-82, 26377-82, and 5803-88.

John Harrison Wegge, Michael Worth Brown, and Maria Heidi Husnak, for petitioners in docket Nos. 16224-82 and 18017-82.

Donna F. Herbert and Mark A. Weiner, for respondent.

OPINION

GERBER, Judge:

Petitioners were part of a large litigation project for which test cases were tried and the issues addressed in a Memorandum Opinion of this Court, Abeson v. Commissioner, T.C. Memo. 1990-190, affd. without published opinion sub nom. Rivera v. Commissioner, 959 F.2d 241 (9th Cir. 1992). Following the opinion on the project issues, which was unfavorable to petitioners, they...

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