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NAFTEL v. COMMISSIONER

Docket No. 28089-82.

85 T.C. 527 (1985)

DONALD A. NAFTEL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 30, 1985.

Attorney(s) appearing for the Case

Joseph F. Moore and Jonathan B. Cole, for the petitioner.

Darren M. Larson, for the respondent.

OPINION

PANUTHOS, Special Trial Judge:1

This case is before the Court on respondent's motion for partial summary judgment filed pursuant to Rule 121.2 By his motion,3 respondent seeks a determination that this Court does not have jurisdiction to consider petitioner's contention that the deficiency determined against him should be credited to the extent of refund...

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