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SAVIANO v. COMMISSIONER

Docket No. 15926-81.

80 T.C. 955 (1983)

ERNEST J. SAVIANO AND MARGARET SAVIANO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 18, 1983.

Attorney(s) appearing for the Case

Lewis H. Ferguson III, Stephen L. Urbanczyk, and Fairlea A. Sheehy, for the petitioners.

Robert R. Rubin and James F. Kidd, for the respondent.

OPINION

SHIELDS, Judge:

Each party has filed a motion for partial summary judgment with respect to the following issues:

(1) Whether or not a nonrecourse obligation undertaken by the petitioner in 1978 is too contingent to be treated as a bona fide indebtedness for tax purposes.

(2) Whether or not petitioner is at risk, under section 465,1 respecting an amount received...

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