ZAENTZ v. COMMISSIONER

Docket No. 3273-86.

90 T.C. 753 (1988)

SAUL ZAENTZ AND LYNDA ZAENTZ, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 21, 1988.


Attorney(s) appearing for the Case

Randall G. Dick and Jeffrey I. Margolis, for the petitioners.

Eugene H. Ciranni and Margaret S. Rigg, for the respondent.


OPINION

NIMS, Judge:

This matter is before the Court on petitioners' motion for partial summary judgment pursuant to Rule 121.1 The requirements of Rule 121 have been satisfied, and we find that a partial summary judgment is appropriate in this case. The issue raised by petitioners' motion is whether statutory closing agreements that settled earlier controversies between petitioners...

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