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REESE v. COMMISSIONER

Docket No. 8523-73.

64 T.C. 395 (1975)

JOHN N. REESE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 12, 1975.

Attorney(s) appearing for the Case

Barring Coughlin and Robert A. Bergquist, for the petitioner.

Alan C. Klein and Larry L. Nameroff, for the respondent.

OPINION

DAWSON, Chief Judge:

This matter is before the Court on motions for summary judgment filed by both parties, and on respondent's alternative objection filed to petitioner's motion for summary judgment. A hearing on the motions was held on March 26, 1975, and they were taken under advisement. Memoranda of law were filed by both parties and evidence regarding Brazilian law was submitted for our consideration.

A statutory notice of deficiency...

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