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TALLAL v. COMMISSIONER

Docket No. 19237-80.

77 T.C. 1291 (1981)

JOSEPH J. TALLAL, JR., AND PAMELA J. TALLAL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 21, 1981.

Attorney(s) appearing for the Case

Robert K. Dowd, for the petitioners.

Douglas R. Fortney, for the respondent.

OPINION

SCOTT, Judge:

This case is before the Court on a motion to dismiss filed by petitioners on March 20, 1981, which, by agreement of the parties, was argued and considered as a motion for summary judgment.

Respondent, by notice mailed to petitioners on July 11, 1980, determined that there was a deficiency in the income tax of Joseph J. Tallal, Jr., and Pamela J. Tallal, for the taxable year ended...

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