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ERHARD v. COMMISSIONER

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

64 T.C.M. 10 (1992)

T.C. Memo. 1992-376.

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

United States Tax Court.

Filed July 6, 1992.

Attorney(s) appearing for the Case

Michael I. Saltzman, Barbara T. Kaplan, 805 Third Ave., New York, N.Y., and Robert F. Hermann, 820 Second Ave., New York, N.Y., for the petitioners. Carmen Baerga, Craig Connell, Mildred Moon, and Raymond Kahn, for the respondent.

Supplemental Memorandum Opinion

SCOTT, Judge:

These cases are before us on petitioners' motion for reconsideration of the Memorandum Findings of Fact and Opinion filed in the above consolidated cases on July 1, 1991, T.C. Memo. 1991-290.

The motion for reconsideration alleged that the Court erred in concluding in its Memorandum Findings of Fact and Opinion (1) that petitioners were not entitled to interest expense...

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