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ZUHOVITZKY v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3489-16.

T.C. Memo. 2018-158

JONATHAN ZUHOVITZKY AND ESTHER ZUHOVITZKY, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 20, 2018.

Attorney(s) appearing for the Case

Ronald J. Cohen and Melissa A. Perry , for petitioners.

Mimi M. Wong , Peter N. Scharff , Shawna A. Early , Stephen C. Huggs , Gerard Mackey , and Lyle B. Press , for respondent.

MEMORANDUM OPINION

This matter is presently before the Court on respondent's motion for partial summary judgment.1 The issue for decision is whether petitioner Esther Zuhovitzky is subject to U.S. tax on her worldwide income in the absence of a section 6013(g) election.

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