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GRUNWALD v. COMMISSIONER

Docket No. 18984-84.

86 T.C. 85 (1986)

RONALD P. GRUNWALD AND SHARON M. GRUNWALD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 28, 1986.

Attorney(s) appearing for the Case

Douglas J. Brajcich and Matthew J. Anderton, for the petitioners.

Henry Thomas Schafer and Phyllis Greenblum, for the respondent.

OPINION

NIMS, Judge:

This matter is before the Court on respondent's motion for partial summary judgment pursuant to Rule 121.1 Petitioners have filed a notice of objection to respondent's motion for partial summary judgment and a cross-motion for partial summary judgment.

Respondent determined deficiencies in petitioners' Federal income tax as follows:


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