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. (continued...)Page: 1 2 3 4 5 6 7 8 9 Next
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