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CUMMINGS v. COMMISSIONER

Docket No. 12449-95.

71 T.C.M. 3193 (1996)

T.C. Memo. 1996-282

Homer N. Cummings v. Commissioner.

United States Tax Court.

Filed June 19, 1996.

Attorney(s) appearing for the Case

Thomas E. Redding, Houston, Tex., for the petitioner. Robert W. West and William A. Heard, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This case is before the Court on (1) Petitioner's Motion for Partial Summary Judgment Regarding Penalties Asserted Based On The Net Operating Loss Carryforwards, filed pursuant to Rule 121(a); and (2) petitioner's Motion for Partial Summary Judgment Regarding The Overvaluation Penalty, also filed pursuant to Rule 121(a).1

Respondent concedes petitioner's second motion for...

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