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ALT v. COMMISSIONER

Docket No. 779-92.

68 T.C.M. 38 (1994)

T.C. Memo. 1994-313

William J. Alt and Rosalinda Alt v. Commissioner.

United States Tax Court.

Filed July 7, 1994.

Attorney(s) appearing for the Case

Stephen M. Lewis, One LaSalle St., Chicago, Ill., for the petitioners. Tanya M. Marcum, for the respondent.

Memorandum Opinion

PARKER, Judge:

This case is before the Court on petitioners' Motion for Leave to File Rule 162 Motion Out of Time. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Background

By statutory notice of deficiency dated...

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