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KRAMER v. COMMISSIONER

Docket No. 26249-81.

89 T.C. 1081 (1987)

DAVID KRAMER AND ANITA KRAMER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 30, 1987.

Attorney(s) appearing for the Case

Robert A. Shupack, for the petitioners.

James R. Rich, for the respondent.

OPINION

GERBER, Judge:

On September 10, 1987, respondent, pursuant to Rule 52,1 moved to strike an allegation in petitioners' amended reply which had been filed, with leave of Court, subsequent to the conclusion of the trial. The amended reply contained a denial of an allegation in respondent's amended answer that an extension of time to assess tax had been executed. If permitted to stand, this allegation by petitioners...

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