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TERM LEASING ASSOCIATES v. COMMISSIONER

Docket No. 22161-90.

64 T.C.M. 822 (1992)

T.C. Memo. 1992-556.

Term Leasing Associates, Sol Henkind, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed September 22, 1992.

Attorney(s) appearing for the Case

Elliot I. Miller, 2425 Post Rd., Southport, Conn., for the petitioner. Jane B. Wilson, for the respondent.

Memorandum Opinion

JACOBS, Judge.

This case was 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 opinion of the Special Trial Judge which is set forth below.

Opinion of the Special Trial Judge

COUVILLION, Special Trial Judge:

This case is a companion case to Henkind v. Commissioner [Dec. 48,521...

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