RETREAT IN MOTION, INC. v. COMMISSIONER

Docket No. 25167-81X.

48 T.C.M. 334 (1984)

T.C. Memo. 1984-315

Retreat in Motion, Inc. v. Commissioner.

United States Tax Court.

Filed June 21, 1984.


Attorney(s) appearing for the Case

James R. Wine (an officer), 2501 S. Harrison St., Fort Wayne, Ind., for the petitioner. Reid M. Huey, for the respondent.


Memorandum Opinion

BUCKLEY, Special Trial Judge:

This is an action for declaratory judgment under section 7428 of the Code.1 It has been decided pursuant to the provisions of section 7456(d) and Rule 218(a).

Consideration of this case was based upon the administrative record as defined in Rule 210(b)(11). The decision, therefore, is based upon the assumption that the facts as represented in the administrative record are...

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