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BOULEZ v. COMMISSIONER

Docket No. 8902-78.

76 T.C. 209 (1981)

PIERRE BOULEZ, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 4, 1981.

Attorney(s) appearing for the Case

Allen Greenberg, for the petitioner.

Theodore J. Kletnick and Anne Hintermeister, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined deficiencies in petitioner's income tax in the amounts of $25,247.68 for the taxable year ended December 31, 1971, and $19,212 for the taxable year ended December 31, 1972. The case is before us on petitioner's motion for summary judgment but, as will subsequently appear, its posture is such that the Court may be in a position to enter a qualified decision for respondent (see note 2 infra).<...

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