SALINE SEWER CO. v. COMMISSIONER

Docket No. 9540-91.

63 T.C.M. 2832 (1992)

T.C. Memo. 1992-236

Saline Sewer Co., James R. and Anne C. Rowland, Tax Matters Person v. Commissioner.

United States Tax Court.

Filed April 21, 1992.


Attorney(s) appearing for the Case

James R. Rowland, pro se. Merle Stolar, for the respondent.


Memorandum Opinion

PARR, Judge:

This matter is before us on petitioners' two motions for partial summary judgment pursuant to Rule 121.1 The following statement of the facts is drawn from the respective written submissions of the parties and is made for purposes of this opinion only. No significant facts are in dispute.

Saline Sewer Company (Saline Sewer) incorporated as a C corporation in 1969. During the relevant years...

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