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SOUTHERN v. COMMISSIONER

Docket No. 15548-84.

87 T.C. 49 (1986)

CHARLES BAXTER SOUTHERN AND DOROTHY I. SOUTHERN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 3, 1986.

Attorney(s) appearing for the Case

William J. Falk, for the petitioners.

Ronald J. Long, for the respondent.

OPINION

HAMBLEN, Judge:

This case is before the Court on petitioners' motion for summary judgement filed on April 15, 1985, pursuant to Rule 121,1 and respondent's motion for partial summary judgment, filed on April 23, 1985, pursuant to Rule 121. In their respective motions, each party claims that summary disposition is appropriate on the issue of the efficacy of a Form 872-A,...

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