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ELKINS v. COMMISSIONER

Docket No. 19384-82.

81 T.C. 669 (1983)

PAUL ELKINS AND JUDITH ELKINS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 28, 1983.

Attorney(s) appearing for the Case

Sidney Gelfand, for the petitioners.

Theodore J. Kletnick and Kendall C. Jones, for the respondent.

OPINION

FEATHERSTON, Judge:

This case is before the Court on respondent's motion for reconsideration of an order, dated May 13, 1983, denying his motion for partial summary judgment pursuant to Rule 121.1 The motion for partial summary judgment raised an issue as to whether the Commissioner properly applied the amended section 1.612-3(b)(3), Income Tax Regs., in disallowing a partnership loss deduction claimed by petitioner...

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