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LINDSAY MANOR NURSING HOME, INC. v. COMM'R

Docket No. 24596-14L.

148 T.C. 235 (2017)

148 T.C. No. 9

LINDSAY MANOR NURSING HOME, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 23, 2017.

Attorney(s) appearing for the Case

David J. Looby , for petitioner.

Ann Louise Darnold , for respondent.

OPINION

This case is before the Court on petitioner's motion for summary judgment under Rule 121.1 The issue for decision is whether section 301.6343-1(b)(4)(i), Proced. & Admin. Regs., is valid.

Background

The record reflects or the parties do not dispute the following...

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