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  5. 863 F.2d 263 (1988)
 

PLEASANT SUMMIT LAND CORP. v. C.I.R.

Nos. 88-1373, 88-1377.

863 F.2d 263 (1988)

PLEASANT SUMMIT LAND CORPORATION, Appellant in 88-1373, v. COMMISSIONER OF INTERNAL REVENUE. George PRUSSIN and Sharon Prussin, Appellants in 88-1377, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided November 25, 1988.

Opinion on Denial of Rehearing January 30, 1989.

Attorney(s) appearing for the Case

Paul Windels, Jr. (argued), John Y. Taggart, Clayton A. Prugh, Windels, Marx, Davies & Ives, New York City, for appellants.

William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen, Jonathan S. Cohen (argued), Michael J. Roach, U.S. Dept. of Justice, Tax Div., Washington, D.C., for appellee.

Before HIGGINBOTHAM, MANSMANN and GREENBERG, Circuit Judges.

Opinion on Denial of Rehearing in No. 88-1377 January 30, 1989.

OPINION OF THE COURT

GREENBERG, Circuit Judge.

Appellants, Pleasant Summit Land Corporation (PSLC) and George and Sharon Prussin, appeal from adverse decisions entered by the Tax Court following a consolidated trial on their petitions to redetermine deficiencies determined by the Commissioner of Internal Revenue. PSLC challenges the Tax Court...

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