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NUNEZ v. C.I.R.

No. CV F-86-404 EDP.

710 F.Supp. 745 (1989)

Henry D. NUNEZ and Cle-Jo Records Partnership, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States District Court, E.D. California.

March 10, 1989.

Attorney(s) appearing for the Case

Craig G. Christensen, Fresno, Cal., for petitioner Cle-Jo Records Partnership.

Thomas F. Carlucci, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent Com'r.

MEMORANDUM DECISION RE: RESPONDENT'S MOTION FOR SUMMARY JUDGMENT

PRICE, District Judge.

Petitioners filed their petition for readjustment of final partnership administrative adjustment on August 13, 1986. The petition recited that the petitioner Cle-Jo Records was a general partnership and that petitioner Henry D. Nunez was a notice partner in Cle-Jo Records.

On August 8, 1988, nearly two (2) years after the action had been filed, a stipulation was...

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