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CENTURY DATA SYSTEMS, INC. v. COMMISSIONER

Docket No. 2682-84.

86 T.C. 157 (1986)

CENTURY DATA SYSTEMS, INC., THROUGH CALIFORNIA COMPUTER PRODUCTS, INC., SUCCESSOR IN LIQUIDATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 11, 1986.

Attorney(s) appearing for the Case

James G. Phillipp and Stephen L. Tolles, for the petitioner.

Michael C. Cohen, for the respondent.

OPINION

NIMS, Judge:

This matter is before the Court on petitioner's motion for judgment on the pleadings pursuant to Rule 120.1 Respondent has submitted, and we have accepted, matters outside the pleadings. We therefore treat petitioner's motion as one for summary judgment pursuant to Rule 121.2

Respondent determined deficiencies in petitioner's Federal income tax as follows:

...

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