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DALTON v. COMMISSIONER

Docket No. 23510-06L.

135 T.C. 393 (2010)

ARTHUR DALTON, JR. AND BEVERLY DALTON, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 23, 2010.

Attorney(s) appearing for the Case

Ralph A. Dyer , for petitioners.

Michael R. Fiore and Erika B. Cormier , for respondent.

SUPPLEMENTAL OPINION

WELLS, Judge:

This case is before the Court on petitioners' motion for summary judgment pursuant to Rule 121.1 Respondent filed a response to petitioners' motion for summary judgment and subsequently filed a second motion for summary judgment.2 The instant proceeding arises from a petition filed in response to Notices of Determination...

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