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MONTANA v. COMMISSIONER

Docket Nos. 5594-91, 9764-91, 24507-91.

67 T.C.M. 2422 (1994)

T.C. Memo. 1994-111

Michael Montana and Susan Montana, et al. v. Commissioner.

United States Tax Court.

Filed March 21, 1994.

Attorney(s) appearing for the Case

Richard S. Kestenbaum and Bernard S. Mark, One Linden Pl., Great Neck, N.Y., for the petitioners. George Soba, for the respondent.

Memorandum Opinion

DAWSON, Judge.

These cases were assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the Chief Special Trial Judge's opinion, which is set forth below.

Opinion of the Chief Special Trial Judge

PANUTHOS, Chief Special Trial Judge.

Respondent...

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