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LAKEWOOD ASSOCIATES v. COMMISSIONER

Docket No. 24656-93.

70 T.C.M. 1381 (1995)

T.C. Memo. 1995-552

Lakewood Associates, Robert G. Moore, Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed November 21, 1995.

Attorney(s) appearing for the Case

Douglas E. Kahle, Virginia Beach, Va., for the petitioner. John C. McDougal, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter originally came before the Court on respondent's Motion for Judgment on the Pleadings filed pursuant to Rule 120(a).1 During the course of a hearing conducted in this case, the parties made certain factual representations to the Court going beyond the matters alleged in the pleadings. Consistent with Rule 120(b),

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