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TOWE v. COMMISSIONER

Docket Nos. 26854-89, 6227-90.

64 T.C.M. 1424 (1992)

T.C. Memo. 1992-689

Andrew C. Towe, Sara Towe Horsfall, Kristin Hartley, Karen James, Thomas E. Towe, James T. Towe, Kristofer E. Towe, Tamara James Jensen, Karla James, David E. James, Eric R. James, Arvid Hartley, Andrew C. Hartley, C. Florence Towe, Towe Farms, Inc. Trust, and Grant Investments Fund v. Commissioner. Towe Farms Inc., Transferee, W. Edward and C. Florence Towe v. Commissioner.

United States Tax Court.

Filed December 2, 1992.

Attorney(s) appearing for the Case

Thomas E. Towe, 2525 Sixth Ave., Billings, Mont., for the petitioners. Jay E. Erickson, for the respondent.

Memorandum Opinion

GERBER, Judge:

Petitioners seek summary judgment in the above-captioned cases with respect to the following issues:1 (1) Whether respondent is precluded from making a gift tax determination concerning the same transaction and taxable periods for which income tax determinations had already been made; (2) whether statements or allegations in a pleading filed...

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