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MOCK DEVELOPMENT PROJECT NO. 1 v. COMMISSIONER

Docket No. 37776-87.

58 T.C.M. 1316 (1990)

T.C. Memo. 1990-49

Mock Development Project No. 1, Fred J. Bresler and Betty J. Bresler; Morris Lawson, Living Trust, Morris Lawson, Trustee; Arthur W. Johnson and Eunice S. Johnson; Francis L. Sargeant and Janet L. Sargeant; Frank Chung Family Trust, Frank Chung, Trustee; and Leslie Taylor, Partners other than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed January 29, 1990.

Attorney(s) appearing for the Case

Thomas Kimmell and John M. Cogswell, for the petitioners. William P. Boulet, Jr., David Monson, and John D. Steele, Jr., 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 Mock Development Project No. 1 ("Mock"). That...

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