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ESTATE OF BEATON v. COMMISSIONER

Docket Nos. 28181-92, 28182-92.

73 T.C.M. 2345 (1997)

T.C. Memo. 1997-140

Estate of James A. Beaton, Deceased, Shirley Beaton, Executrix, and Shirley Beaton v. Commissioner. Alan B. Steiner and Barbara W. Steiner v. Commissioner.

United States Tax Court.

Filed March 18, 1997.

Attorney(s) appearing for the Case

Michael I. Sanders, Washington, D.C., Craig A. Etter, and Timothy J. Jessell, for the petitioners. Kathleen E. Whatley, the for respondent.

MEMORANDUM OPINION

CHABOT, Judge:

This matter is before the Court on respondent's motions for partial summary judgment1 under Rule 121.2 The instant cases have been consolidated for opinion.

Respondent asks the Court to determine that, on the date the notices of deficiency were issued, the statute of limitations for assessment of Federal income tax had closed petitioners' 1985 year and that...

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