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LAW v. COMMISSIONER

Docket Nos. 17315-82, 10054-83.

84 T.C. 985 (1985)

WILLIAM J. LAW AND HELEN M. LAW, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 23, 1985.

Attorney(s) appearing for the Case

Rex A. Guest, for the petitioners.

David D. Baier, for the respondent.

OPINION

SIMPSON, Judge:

On March 28, 1985, the Commissioner filed a "Motion for Leave to File Second Amendment to Answer," pursuant to Rule 41(a) of the Tax Court Rules of Practice and Procedure.1 He seeks leave to amend his answer to assert the applicability of section 6621(d), I.R.C. 1954,2 as added by section 144 of the Tax Reform Act of 1984, Pub...

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