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GREENBERG'S EXPRESS, INC. v. COMMISSIONER

Docket Nos. 4006-72, 4036-72, 4038-72, 4055-72, 4220-72, 4245-72, 4269-72, 4286-72, 5538-72.

62 T.C. 324 (1974)

GREENBERG'S EXPRESS, INC., ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 18, 1974.

Attorney(s) appearing for the Case

Morton A. Smith and Samuel J. Friedman, for the petitioners.

Steedly Young, for the respondent.

OPINION

TANNENWALD, Judge:

These cases are before us on petitioners' motion for a protective order under Rule 103(a)(10), Tax Court Rules of Practice and Procedure. We deny the motion for the reasons stated below and append some additional comments which we hope will facilitate the further proceedings in these cases.

The substantive gravamen of petitioners' complaint is that the deficiency notices involved herein stem from second examinations...

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