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MALLORY v. COMMISSIONER

Docket No. 21978-81.

46 T.C.M. 99 (1983)

T.C. Memo. 1983-257

Peter Mallory and Jean Mallory v. Commissioner.

United States Tax Court.

Filed May 9, 1983.

Attorney(s) appearing for the Case

Peter Mallory, Fallbrook, Calif., for the petitioners. Patrick C. McGovern, for the respondent.

Memorandum Opinion

WILES, Judge:

This case is before us on respondent's motion for summary judgment filed on March 2, 1982, pursuant to Rule 121,1 and heard on February 14, 1983.

Petitioners Peter Mallory and Jean Mallory, husband and wife, resided in Fallbrook, California, when they filed their petition and amended petition in this case.

On December 4, 1980, respondent notified petitioners by letter that their...

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