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TUTOR-SALIBA CORP. v. COMMISSIONER

Docket No. 3110-98.

115 T.C. 1 (2000)

TUTOR-SALIBA CORPORATION, A CALIFORNIA CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 17, 2000.

Attorney(s) appearing for the Case

Marilyn Barrett, for petitioner.

Steven M. Roth and Jonathan H. Sloat, for respondent.

OPINION

GERBER, Judge:

Pursuant to Rule 121,1 this matter is before the Court on petitioner's motion for partial summary judgment. The parties seek to determine, as a matter of law, whether section 1.460-6(c)(2)(vi)(A) and (B), Income Tax Regs., is invalid to the extent it contains no requirement that disputed long-term contract claims meet the "all events test" to be includable...

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