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BHADA v. COMMISSIONER

Docket Nos. 22588-86, 22589-86.

89 T.C. 959 (1987)

ROHINTON K. BHADA AND PATRICIA A. BHADA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT EDWARD J. CAAMANO AND JANICE W. CAAMANO, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 5, 1987.

Attorney(s) appearing for the Case

John P. Carroll, Jr., Richard M. Fabbro, and Leslie J. Hoffman, for the petitioners.

Alfred C. Bishop, Jr., for the respondent.

OPINION

NIMS, Judge:

This matter is before the Court on the parties' cross-motions for partial summary judgment pursuant to Rule 121.1 The parties have complied with the requirements of Rule 121, and we find that a partial summary judgment is appropriate in this case. The issue raised by each motion is whether the shares of International common stock received by petitioners in exchange for McDermott common stock constitute...

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