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ALESSANDRA v. COMMISSIONER

Docket Nos. 13808-82, 12407-83, 431-90.

68 T.C.M. 1288 (1994)

T.C. Memo. 1994-584

Albert J. and Marie A. Alessandra v. Commissioner.

United States Tax Court.

Filed December 1, 1994.

Attorney(s) appearing for the Case

F. Whitten Peters for petitioner Albert J. Alessandra. William M. Wiltshire, for petitioner Albert J. Alessandra in Docket Nos. 13808-82 and 12407-83 only. W. James Slaughter and Donald E. Slaughter, for petitioner Marie A. Alessandra. Wilton A. Baker, for the respondent.

Memorandum Opinion

PANUTHOS, Chief Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183,1 and comes before the Court on petitioner Albert J. Alessandra's (petitioner) Motion for Partial Summary Judgment filed pursuant to Rule 121, in which petitioner Marie J. Alessandra joins. For simplicity, we refer to the motions in the singular as the motion filed by petitioner...

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