United States Tax Court January 4, 1993, Docket No. 4111-84 (Malamed)

KENNETH D. AND SANDRA G. MALAMED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Malamed Docket No. 4111-84 United States Tax Court T.C. Memo 1993-1; 1993 Tax Ct. Memo LEXIS 4; 65 T.C.M. (CCH) 1693; January 4, 1993, Filed *4 For Petitioner: Mark Bernsley. For Respondent: Donna F. Herbert FAY FAY MEMORANDUM OPINION FAY, Judge: This case was assigned to Special Trial Judge Larry L.