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SARCHAPONE v. COMMISSIONER

Docket No. 753-82.

46 T.C.M. 883 (1983)

T.C. Memo. 1983-446

William Sarchapone and Joann Sarchapone v. Commissioner.

United States Tax Court.

Filed July 27, 1983.

Attorney(s) appearing for the Case

Chester Kosarek, Jr., for the petitioners. Alfred Pierri, for the respondent.

Memorandum Opinion

DAWSON, Chief Judge:

This matter is before us on respondent's motion for summary judgment pursuant to Rule 1211 filed April 29, 1983, and petitioners' oral motion for relief from deemed admissions under Rule 90(e). Both motions were heard at Newark, New Jersey on May 24, 1983.

In a statutory notice of deficiency dated October 23, 1981, respondent determined the following deficiency in petitioners' Federal...

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