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HANRAHAN v. COMMISSIONER

Docket No. 12574-81.

50 T.C.M. 877 (1985)

T.C. Memo. 1985-440

Homer E. and Roberta S. Hanrahan v. Commissioner.

United States Tax Court.

Filed August 21, 1985.

Attorney(s) appearing for the Case

Homer E. Hanrahan, pro se. Thomas C. Borders, for the respondent.

Memorandum Opinion

PAJAK, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7456 and Rule 180 for purposes of ruling on respondent's Motion for Summary Judgment, filed pursuant to Rule 121.1 Petitioners filed a Notice of Objection. After careful review of the record, we find that there are two separate issues. For the reasons set forth below, we shall grant respondent's motion in part.

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