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BLOUNT v. COMMISSIONER

Docket No. 34916-84.

86 T.C. 383 (1986)

SHERWOOD E. BLOUNT, JR., AND PHYLLIS B. BLOUNT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 13, 1986.

Attorney(s) appearing for the Case

Larry Hercules and Edward Lavery, for the petitioners.

William Hardeman, for the respondent.

OPINION

JACOBS, Judge:

This case is before us on petitioners' motion for summary judgment under Rule 121(a)1. As the parties have stipulated to all the pertinent facts, there is no genuine issue as to any material fact; therefore, a decision may be rendered as a matter of law. Rule 121(b).

The sole issue involved is whether the period for assessing a deficiency against the petitioners for 1980 expired prior to...

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