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KELLY v. COMMISSIONER

Docket No. 17679-81.

46 T.C.M. 1391 (1983)

T.C. Memo. 1983-569

Charles J. Kelly and Deborah A. Kelly v. Commissioner.

United States Tax Court.

Filed September 14, 1983.

Attorney(s) appearing for the Case

Deborah Kelly, pro se, Bridgeville, Pa. Edward F. Peduzzi, Jr., for the respondent.

Memorandum Opinion

WHITAKER, Judge:

This case is before us on respondent's motions for partial summary judgment and to dismiss for lack of prosecution. The motions were filed on March 14, 1983, pursuant to Rules 121 and 123, respectively.1 For convenience we have combined our Findings of Fact and Opinion.

In his notice of deficiency dated April 15, 1981, respondent determined deficiencies in petitioners' income tax and...

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