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SOLIS v. COMMISSIONER

Docket No. 12102-94.

70 T.C.M. 362 (1995)

T.C. Memo. 1995-380

Sebastian and Juana Solis v. Commissioner.

United States Tax Court.

Filed August 10, 1995.

Attorney(s) appearing for the Case

Franklin R. Hise and Blaise Gately Dusenberry, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is presently before the Court on respondent's Motion for Partial Summary Judgment that petitioners are liable for a penalty for fraud under section 6663(a) for the taxable year 1990.1 As explained in more detail below, we agree with respondent that partial summary judgment is appropriate.

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