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GRALNEK v. COMMISSIONER

Docket Nos. 14467-85, 37361-85, 16974-86.

58 T.C.M. 1309 (1990)

T.C. Memo. 1990-46

David E. Gralnek and Barbara C. Gralnek, et al. v. Commissioner.

United States Tax Court.

Filed January 25, 1990.

Attorney(s) appearing for the Case

Stephen E. Silver, Brad S. Ostroff, 702 East Osborn Road, Phoenix, Ariz., Arthur P. Allsworth, 1 East Camelback, Phoenix, Ariz., and Robert J. Lord, for the petitioners. David W. Otto, for the respondent.

Memorandum Opinion

HAMBLEN, Judge:

This matter is before the Court on petitioners' motion for reconsideration of our opinion filed August 16, 1989, [Dec. 45,947(M)] T.C. Memo. 1989-433, and respondent's response to petitioners' motion for reconsideration. In that opinion we decided, among other things, that the entity known as Baillie Associates, Inc. (BAI) should be disregarded for purposes of determining whether petitioners...

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