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ALLISON v. COMMISSIONER

Docket Nos. 23762-91, 23763-91.

65 T.C.M. 1827 (1993)

T.C. Memo. 1993-35

William A. Allison and Kathleen E. Allison v. Commissioner.

United States Tax Court.

Filed February 1, 1993.

Attorney(s) appearing for the Case

William A. Allison and Kathleen E. Allison, pro se. John W. Duncan, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:

These cases were assigned pursuant to section 7443A(b)(4).1 The cases are before the Court on respondent's Motion for Judgment on the Pleadings in Docket No. 23762-91 and Motion for Partial Summary Judgment in Docket No. 23763-91. The facts may be summarized as follows.

By notices of deficiency dated July 25, 1991, respondent determined deficiencies and additions to tax...

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