Court of Appeals for the Tenth Circuit June 30, 1995, 94-9017 (Janis G. Berend and Randolph J. Berend v. Commissioner of Internal Revenue)

59 F.3d 178 76 A.F.T.R.2d 95-5730 NOTICE: Although citation of unpublished opinions remains unfavored, unpublished opinions may now be cited if the opinion has persuasive value on a material issue, and a copy is attached to the citing document or, if cited in oral argument, copies are furnished to the Court and all parties. See General Order of November 29, 1993, suspending 10th Cir. Rule 36.