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KARLSSON v. COMMISSIONER

Docket Nos. 16542-86, 45989-86.

74 T.C.M. 694 (1997)

T.C. Memo. 1997-432

Pelle Karlsson and Evelyn T. Karlsson v. Commissioner.

United States Tax Court.

Filed September 23, 1997.

Attorney(s) appearing for the Case

Mark D. Pastor, Encino, Calif., and Robert T. Leonard, for the petitioners. Elizabeth Girafalco Chirich, Susan K. Greene, Karen M. Tate, and Marion S. Friedman, for the respondent.

MEMORANDUM OPINION

SWIFT, Judge:

This matter is before us on our order to show cause why resolution of the issues in these consolidated cases should not be controlled by resolution of these same issues in our test case opinion in Krause v. Commissioner [Dec. 48,383], 99 T.C. 132 (1992), affd. sub nom. Hildebrand v. Commissioner [94-2 USTC ¶ 50,305],

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