ERHARD v. COMMISSIONER

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

65 T.C.M. 1786 (1993)

T.C. Memo. 1993-25

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

United States Tax Court.

Filed January 21, 1993.


Attorney(s) appearing for the Case

Michael I. Saltzman, Barbara T. Kaplan, 1 Chase Manhattan Plaza, New York, N.Y., and Robert F. Hermann, 820 2nd Ave., New York, N.Y., for the petitioners. Carmen Baerga, Craig Connell, Mildred Moon, and Raymond Kahn, for the respondent.


Second Supplemental Memorandum Opinion

SCOTT, Judge:

The Memorandum Findings of Fact and Opinion in these cases, T.C. Memo. 1991-290, was filed July 1, 1991. Petitioners timely filed a motion for reconsideration and a hearing on this motion was held on October 30, 1991. The Court granted the motion for reconsideration with respect to the allegation therein that the Court erred in holding that petitioners had not established...

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