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FELDMAN v. COMMISSIONER

Docket No. 23586-83.

49 T.C.M. 1012 (1985)

T.C. Memo. 1985-132

Joseph H. Feldman and Diane Feldman v. Commissioner.

United States Tax Court.

Filed March 25, 1985.

Attorney(s) appearing for the Case

John T. West, for the petitioners. Michael N. Balsamo and Phyllis W. Greenblum, for the respondent.

Memorandum Opinion

CANTREL, Special Trial Judge:

This case is before the Court on petitioners' Motion for Summary Judgment pursuant to Rule 121, filed on January 17, 1985, which was called from the calendar at the Motions Session of the Court at Washington, D. C. on March 6, 1985.1 Because the motion was improperly characterized, we will recharacterize it, and deem it a Motion for Partial Summary Judgment pursuant to Rule 121...

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