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BLAK INVESTMENTS v. COMMISSIONER

No. 1283-07.

133 T.C. 431 (2009)

BLAK INVESTMENTS, KYLE W. MANROE TRUST, ROBERT AND LORI MANROE, TRUSTEES, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 23, 2009.

Attorney(s) appearing for the Case

Ernest S. Ryder , Richard V. Vermazen , and Lauren A. Rinsky , for petitioner.

Donna F. Herbert and Jonathan H. Sloat , for respondent.

OPINION

HAINES, Judge.

This case is before the Court on respondent's motion and petitioner's cross-motion for partial summary judgment filed pursuant to Rule 121.1 The issues are:

(1) Whether the effective date of section 6707A precludes application of section 6501(c)(10) to the transaction at issue; (2) whether the transaction at issue is a listed transaction; and (3) whether the period of limitations for assessment...

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