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O'CONNOR v. COMMISSIONER

Docket No. 24124-90.

64 T.C.M. 237 (1992)

T.C. Memo. 1992-410

John R. O'Connor v. Commissioner.

United States Tax Court.

Filed July 20, 1992.

Attorney(s) appearing for the Case

B. Gray Gibbs, for the petitioner. Richard G. Goldman and Steve R. Johnson, for the respondent.

Memorandum Opinion

NIMS, Judge:

This case is before the Court on respondent's motion to strike filed pursuant to Rule 52. (Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, section references are to sections of the Internal Revenue Code in effect for the years in issue.)

In addition to respondent's motion to strike and petitioner's notice of objection thereto, the parties have filed memoranda of law...

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