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KLUESNER v. COMMISSIONER

Docket No. 5383-87, 6237-87.

56 T.C.M. 1354 (1989)

T.C. Memo. 1989-83

Virgil A. Kluesner and Mary J. Kluesner v. Commissioner. CPT Corporation v. Commissioner.

United States Tax Court.

Filed February 27, 1989.

Attorney(s) appearing for the Case

Michael J. Mollerus, 7600 Parklawn Ave., Edina, Minn., and Allan R. Poncin, for the petitioners in Docket No. 5383-87. John S. Jagiela and Mark A. Kimball, 45 S. 7th St., Minneapolis, Minn., for the petitioner in Docket No. 6237-87. Charles M. Berlau, for the respondent.

Memorandum Opinion

WILLIAMS, Judge:

This case is before us on petitioner CPT Corporation's motion for summary judgment and petitioners Virgil A. Kluesner's and Mary J. Kluesner's cross-motion for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The Commissioner is a stakeholder in this controversy; he determined deficiencies in petitioners Kluesners' Federal income tax for their 1980 taxable year in the amount of $59...

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