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MERRILL v. COMMISSIONER

Docket No. 8956-89.

58 T.C.M. 558 (1989)

T.C. Memo. 1989-590

Joseph S. and Yvonne Y. Merrill v. Commissioner.

United States Tax Court.

Filed October 30, 1989.

Attorney(s) appearing for the Case

Calder L. Robertson, Jr., for the respondent.

Memorandum Opinion

GUSSIS, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss for Failure to State a Claim upon which Relief can be Granted, filed June 12, 1989. See Rule 40.1 On July 24, 1989, petitioners filed their opposition to respondent's motion. Respondent presented argument at a hearing held by the Court on July 26, 1989.

Petitioners...

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