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AVON LAND COMPANY, LTD. v. COMMISSIONER

Docket Nos. 16582-90, 16583-90.

64 T.C.M. 1189 (1992)

T.C. Memo. 1992-634

Avon Land Company, Ltd., Steve K. and Diane W. Smith, Partners Other Than the Tax Matters Partner v. Commissioner. Mark XV Company, Steve K. and Diane W. Smith, Partners Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed October 27, 1992.

Attorney(s) appearing for the Case

Steve K. Smith, pro se, Timothy S. Sinnott, for the respondent.

Memorandum Opinion

GERBER, Judge:

These cases are before us on respondent's motions for order to show cause why judgment should not be entered against petitioners on the basis of a previously decided case. By order dated October 22, 1991, we granted respondent's motions and ordered petitioners to show cause why judgment should not be entered against petitioners on the basis of the Court's decision in Smith v. Commissioner [Dec. 47,580(M)],

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