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HENKIND v. COMMISSIONER

Docket Nos. 6299-89, 6337-89.

64 T.C.M. 807 (1992)

T.C. Memo. 1992-555

Sol Henkind and Evelyn Henkind v. Commissioner. David B. Simpson and Nancy S. Simpson v. Commissioner.

United States Tax Court.

Filed September 22, 1992.

Attorney(s) appearing for the Case

Elliot I. Miller and Robert T. Gradoville, 2425 Post Rd., Southport, Conn., for the petitioners. Jane Beaver Wilson, Mark L. Hulse, and Dean Scott, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

These cases were assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The Court agrees with and adopts the Special Trial Judge's opinion which is set forth below.

Opinion of the Special Trial Judge

COUVILLION, Special Trial Judge:

In these consolidated cases, respondent determined deficiencies...

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