T.C. Memo. 1996-2
UNITED STATES TAX COURT
DAROLD D. FRIESEN AND ROSELLA M. FRIESEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14372-95. Filed January 3, 1996.
Peter Reilly and Albert B. Kerkhove, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This case is before the Court
on respondent's Motion To Dismiss For Failure To State A Claim
Upon Which Relief Can Be Granted, filed pursuant to Rule 40.1
1 All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the taxable years in issue.
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