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PODELL v. COMMISSIONER

Docket No. 5450-85.

52 T.C.M. 1364 (1987)

T.C. Memo. 1987-22

Jonathan and Monica Podell v. Commissioner.

United States Tax Court.

Filed January 12, 1987.

Attorney(s) appearing for the Case

William L. Mander, for the petitioners. Frank Agostino and Will E. McLeod, for the respondent.

Memorandum Opinion

GOLDBERG, Special Trial Judge:

This case is before the Court on respondent's Motion For Partial Summary Judgment, pursuant to Rule 121,1 filed on March 18, 1986. The motion was calendared for hearing at the Motions Session in Washington, D.C. on April 30, 1986. On April 17, 1986, petitioners filed an objection to respondent's motion which contained a cross-motion for summary judgment and a written statement...

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