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COFFEY v. COMMISSIONER

Docket No. 11846-87.

96 T.C. 161 (1991)

DONALD R. COFFEY AND JANIS I. COFFEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 28, 1991.

Attorney(s) appearing for the Case

Ronald M. Mankoff, G. Tomas Rhodus, and Ronald A. Stein, for the petitioners.

James E. Archie and Donna S. Robason, for the respondent.

OPINION

GERBER, Judge:*

This case was part of a larger group of related cases bearing the designation "First Western Government Securities." Petitioners filed a motion for summary judgment seeking a dismissal on jurisdictional grounds. There is no dispute as to the facts concerning the motion for summary judgment and the subject issue is ripe for resolution. More specifically,...

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