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GREENE v. COMMISSIONER

Docket No. 14750-79.

81 T.C. 132 (1983)

LORNE GREENE AND NANCY GREENE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 23, 1983.

Attorney(s) appearing for the Case

Eugene D. Silverman and Morris Engel, for the petitioners.

Marshall W. Taylor, for the respondent.

OPINION

SIMPSON, Judge:

This matter is before the Court on the parties' cross motions for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1 The sole issue raised by the motions is whether Alpha Film Co. (Alpha) is entitled to a depreciation deduction for 1975 under the income forecast method.

The Commissioner determined a deficiency of $9,195 in the petitioners' Federal...

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