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DALTON DEVELOPMENT PROJECT NO. 1 v. COMMISSIONER

Docket No. 37777-87.

58 T.C.M. 1311 (1990)

T.C. Memo. 1990-47

Dalton Development Project No. 1; Donald G. Prior and Lois A. Prior; Laverne W. Roth and Lucille M. Roth; Roger W. Lindner and Carole A. Lindner; Jose A. Ferreira and Ines R. Ferreira; Esther S. Morgan; Rhode C. Ramirez; Robert P. Davis and Margaret J. Davis; and Robert Middleton, Partners other than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed January 29, 1990.

Attorney(s) appearing for the Case

Peter M. Eggleston and John M. Cogswell, 1700 Lincoln St., Denver, Colo., for the petitioners. William P. Boulet, Jr., David Monson, and Patrick W. Lucas, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

This matter is before the Court on petitioners'1 Motion for Summary Judgment filed pursuant to Rule 121.2 The sole issue for decision is whether it is appropriate to grant petitioners' motion for summary judgment on the grounds that the period for assessment had expired for the 1982 taxable year of Dalton Development Project No. 1 ("Dalton")....

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