T.C. Memo. 1996-282 UNITED STATES TAX COURT HOMER N. CUMMINGS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12449-95. Filed June 19, 1996. Thomas E. Redding, for petitioner. Robert W. West and William A. Heard, for 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 forPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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