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MORGAN v. COMMISSIONER

Docket No. 18593-91.

63 T.C.M. 3183 (1992)

T.C. Memo. 1992-362

Bruce R. Morgan, as Possessor of Certain Cash v. Commissioner.

United States Tax Court.

Filed June 24, 1992.

Attorney(s) appearing for the Case

John Gigounas, 50 California St., San Francisco, Calif., and Edward B. Simpson, for the petitioner.

Debra A. Bowe, for the respondent.

Memorandum Opinion

SWIFT, Judge.

This case is before us on petitioner's motion for summary judgment. On June 13, 1991, respondent, pursuant to sections 6851 and 68671, issued a notice of deficiency to petitioner in the amount of $53,732.

The primary issue raised by petitioner's motion for summary judgment is whether the exclusionary rule should apply in this proceeding to bar respondent from introducing certain illegally...

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