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LIMMER v. COMMISSIONER

Docket No. 37609-85.

52 T.C.M. 1269 (1986)

T.C. Memo. 1986-605

Charles M. and Susan G. Limmer v. Commissioner.

United States Tax Court.

Filed December 30, 1986.

Attorney(s) appearing for the Case

Judy Jacobs, for the respondent.

Memorandum Findings of Fact and Opinion

GOLDBERG, Special Trial Judge:

This case was heard pursuant to the provisions of section 7456(d) (redesignated as section 7443A by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. ___) and Rule 180 et seq.1 This case is before the Court on respondent's Motion For Summary Judgment filed on May 23, 1986.

Background

In a notice of deficiency dated...

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