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HIRASUNA v. COMMISSIONER

Docket Nos. 27047-83, 16242-85.

89 T.C. 1216 (1987)

JOHN HIRASUNA AND CLAUDIA HIRASUNA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HARRY H. HATASAKA AND SADAKO M. HATASAKA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 28, 1987.

Attorney(s) appearing for the Case

Montie S. Day, for the petitioners.

Erik P. Doerring, for the respondent.

OPINION

PARR, Judge:

These consolidated cases are before the Court on petitioners' motion for summary judgment filed on December 18, 1986, and respondent's cross-motion for partial summary judgment filed on March 9, 1987. Both petitioners' motion and respondent's cross-motion included a memorandum of law, affidavits, and exhibits. Petitioners filed a memorandum in reply to respondent's cross-motion on May 12, 1987.

In a notice of deficiency...

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