Memorandum Opinion
WILES, Judge:
This matter is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief can be granted, filed on September 28, 1981, pursuant to Rule 40
Petitioners Robert J. Sidle, Jr. and Sandra L. Sidle, husband and wife, resided in Austin, Texas, on the date they filed their petition in this case. They filed a joint Federal income...
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