[1]     

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT August Term, 1994

, [5]     

Argued: June 13, 1995

, [6]      RICHARD L. SIMON AND FIONA SIMON, PETITIONERS-APPELLEES v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLANT. " />

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Simon v. Commissioner of Internal Revenue


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