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BURFORD v. COMMISSIONER

Docket No. 12466-80.

48 T.C.M. 1001 (1984)

T.C. Memo. 1984-466

S. Franklin Burford and Fern J. Burford v. Commissioner.

United States Tax Court.

Filed September 4, 1984.

Attorney(s) appearing for the Case

Michael E. Caryl, Arnold K. Mytelka, Alan Rubin, Gerald H. Litwin and Jeffry M. Schwartz, for petitioner S. Franklin Burford. Bertram L. Potemken, for petitioner Fern J. Burford.

Cynthia J. Mattson and Ronald D. Pinsky, for the respondent.

Memorandum Opinion

SCOTT, Judge:

This case is before the Court on respondent's motion for partial summary judgment, filed December 16, 1983, pursuant to Rule 121.1 The record shows that respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1976 in the amount of $328,702.56. One of numerous adjustments in the notice of deficiency was the disallowance of $470,442 of a loss claimed by petitioner...

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