SOCIETY OF COSTA RICA COLLECTORS v. COMMISSIONER

Docket No. 8531-83X.

49 T.C.M. 304 (1984)

T.C. Memo. 1984-648

Society of Costa Rica Collectors v. Commissioner.

United States Tax Court.

Filed December 13, 1984.


Attorney(s) appearing for the Case

Charles G. Trenckmann, 717 Brown Bldg., Austin, Tex. 78701, for the petitioner. David A. Hampel and Mark L. Puryear, for the respondent.


Memorandum Opinion

GUSSIS, Special Trial Judge:

This is an action for declaratory judgment1 under section 7428 of the Code.2 It has been decided pursuant to assignment under the provisions of section 7456(d)(1) and Rule 218(a). Pursuant to Court Order this case was submitted on the basis of the administrative record filed September 28, 1983. The issue...

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