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VALLONE v. COMMISSIONER

Docket No. 24111-84.

88 T.C. 794 (1987)

GERALD W. AND ELIZABETH R. VALLONE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 6, 1987.

Attorney(s) appearing for the Case

Alan Jay Weil and Steven S. Davis, for the petitioners.

Thomas D. Coker, for the respondent.

OPINION

WRIGHT, Judge:

This matter is before the Court on petitioners' motion for summary judgment, or alternatively, for an order suppressing evidence, and respondent's cross-motion for partial summary judgment, each filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1

By notice of deficiency dated April 9, 1984, respondent determined the following deficiencies and additions to tax in petitioners...

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