LINDSAY MANOR NURSING HOME, INC. v. COMM'R

Docket No. 24596-14L.

148 T.C. 235 (2017)

148 T.C. No. 9

LINDSAY MANOR NURSING HOME, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 23, 2017.


Attorney(s) appearing for the Case

David J. Looby, for petitioner.

Ann Louise Darnold, for respondent.


OPINION

This case is before the Court on petitioner's motion for summary judgment under Rule 121.1 The issue for decision is whether section 301.6343-1(b)(4)(i), Proced. & Admin. Regs., is valid.

Background

The record reflects or the parties do not dispute the following...

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