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CHENG v. COMMISSIONER

Docket No. 24207-82.

51 T.C.M. 861 (1986)

T.C. Memo. 1986-153

William P. Cheng v. Commissioner.

United States Tax Court.

Filed April 17, 1986.

Attorney(s) appearing for the Case

Eugene D. Silverman and William W. Holcomb, for the petitioner. John F. O'Brien, Willard J. Frank, and Robert B. Dugan, for the respondent.

Memorandum Opinion

CLAPP, Judge:

In a notice of deficiency, dated July 16, 1982, respondent determined deficiencies in petitioner's Federal income tax of $8,297 for 1977 and $22,679 for 1978.

This case is before the Court on respondent's motion for partial summary judgment, and petitioner's cross-motion for partial summary judgment, each filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure...

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