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MILLER v. COMMISSIONER

Docket No. 22733-92.

73 T.C.M. 2319 (1997)

T.C. Memo. 1997-134

Albert J. Miller v. Commissioner.

United States Tax Court.

Filed March 17, 1997.

Attorney(s) appearing for the Case

Lawrence V. Brookes, for the petitioner. Ewan D. Purkiss and Andrew P. Crousore, for the respondent.

MEMORANDUM OPINION

KÖRNER, Judge:

This case is before the Court on petitioner's motion for summary judgment as supplemented under Rule 121.1 Respondent determined that petitioner, acting as general partner of certain limited partnerships, was personally liable under section 1461 for his failure to withhold tax due under section 881, as required by section 1442, on payments made by such limited partnerships to A-Alphatronics...

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