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SENESI v. COMMISSIONER

Docket No. 363-81.

43 T.C.M. 143 (1981)

T.C. Memo. 1981-723

Phyllis J. Senesi and Stephen M. Senesi v. Commissioner.

United States Tax Court.

Filed December 23, 1981.

Attorney(s) appearing for the Case

Phyllis J. Senesi and Stephen M. Senesi, pro se, Kalamazoo, Mich. F. Michael Kovach, Jr., for the respondent.

Memorandum Opinion

PARKER, Judge:

This matter is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief may be granted, filed on February 11, 1981, pursuant to Rules 40 and 53, Tax Court Rules of Practice and Procedure.1 At the hearing on October 26, 1981, respondent filed a memorandum in support of his motion, and petitioners filed a written response to respondent's motion with an attached...

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