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  5. 52 T.C.M. 534 (1986)
 

NOONAN v. COMMISSIONER

Docket Nos. 16879-83, 31318-84, 34490-84, 126-85, 6123-85, 8339-85, 10859-85, 12358-85, 13473-85, 15725-85, 18606-85, 24858-85, 35031-85, 4957-86, 8227-86.

52 T.C.M. 534 (1986)

T.C. Memo. 1986-449

Donal C. Noonan and Ruth H. Noonan, et al. v. Commissioner.

United States Tax Court.

Filed September 17, 1986.

Attorney(s) appearing for the Case

Martin N. Gelfand and William M. Weintraub, for the petitioners. Martin D. Cohen and William H. Quealy, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

COHEN, Judge:

These consolidated "test case petitioners" were selected by counsel and approved by the Court to serve as test cases for resolving numerous issues common to a much larger group of petitioners who invested during 1980 through 1982 in refrigerated intermodal containers marketed by or on behalf of Food-Source, Inc. Appendix A sets forth petitioners by name...

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