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ANONYMOUS v. COMMISSIONER

Docket No. 28246-07D.

134 T.C. 13 (2010)

ANONYMOUS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 19, 2010.

Attorney(s) appearing for the Case

Sealed, for petitioner.

Sealed, for respondent.

OPINION

GOEKE, Judge:

This matter is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121.1 For the reasons stated herein, we shall grant in part and deny in part respondent's motion.

Background

On October 1, 2004, petitioner submitted a request for a private letter ruling (PLR). On September 17, 2007, respondent contacted petitioner to inform petitioner that...

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