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O'NEAL v. COMMISSIONER

Docket Nos. 15753-92, 15760-92, 15761-92, 15803-92, 15849-92, 15851-92, 16145-92.

102 T.C. 666 (1994)

KIRKMAN O'NEAL II, DONEE/TRANSFEREE, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 28, 1994.

Attorney(s) appearing for the Case

David D. Aughtry and Roy J. Crawford, for petitioners.

Michael T. Breen, David Delduco, and J. Mack Karesh, for respondent.

OPINION

SCOTT, Judge:

Pursuant to Rule 121,2 this matter is before the Court on respondent's motion for partial summary judgment (respondent's motion) and petitioners' cross-motion for summary judgment (petitioners' motion), filed September 8, 1993, and September 27, 1993, respectively. On October 18, 1993, petitioners filed a second motion for summary judgment (petitioners' second...

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