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NABAKOWSKI v. COMMISSIONER

Docket No. 19893-80.

45 T.C.M. 427 (1982)

T.C. Memo. 1982-743

Edward W. Nabakowski and Sue M. Nabakowski v. Commissioner.

United States Tax Court.

Filed December 30, 1982.

Attorney(s) appearing for the Case

Michel G. Emmanuel, P.O. Box 3239, Tampa, Fla., for the petitioner. David R. Smith, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

This case is before the Court on respondent's motion for summary judgment and petitioners' cross-motion for summary judgment pursuant to Rule 121.1 Respondent determined a deficiency in petitioners' joint Federal income tax for 1975 in the amount of $401,482. The only issues in dispute are (1) whether petitioners are entitled to a deduction for depreciation

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