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SHIOSAKI v. COMMISSIONER

Docket Nos. 346-71, 8440-71, 4476-73.

61 T.C. 861 (1974)

JAMES T. SHIOSAKI, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 28, 1974.

Attorney(s) appearing for the Case

James T. Shiosaki, pro se.

Stephen B. Zorick, Jr., for the respondent.

OPINION

SIMPSON, Judge:

The respondent has made a timely motion for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure,1 in these three cases, which all involve the same petitioner and the same issue.

The petitioner has been before this Court in a prior case, James T. Shiosaki, T.C. Memo. 1971-24. In that case, the petitioner had incurred...

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