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JUPITER 8, INCORPORATED v. COMMISSIONER

Docket No. 45548-86.

56 T.C.M. 386 (1988)

T.C. Memo. 1988-476

Jupiter 8, Incorporated v. Commissioner.

United States Tax Court.

Filed September 28, 1988.

Attorney(s) appearing for the Case

Jupiter 8, Incorporated, Alpha Bldg., Easton, Pa., for petitioner. Sandy E. Freund, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:1

This case is before the Court on petitioner's Motion for Partial Summary Judgment under Rule 121.2 The essential question is whether Gilbert Rifkin had the authority to execute a Form 870 on August 23, 1978. The facts are as follows:

On October 10, 1977, petitioner's president, Robert David Morton, executed a Form 2848 appointing Gilbert Rifkin...

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