T.C. Memo. 1996-458
UNITED STATES TAX COURT
OCEANIC LEASING, DOUGLAS F. SPAULDING, TAX MATTERS
PARTNER, Petitioner v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 4219-93. Filed October 10, 1996.
George Mac Vogelei and Phillip J. Terry, for petitioner and
for Arthur Willner, a moving party.
Christian A. Speck, for respondent.
MEMORANDUM OPINION
COHEN, Chief Judge: Following settlement with the
participating parties to this proceeding, respondent filed a
Motion for Entry of Decision pursuant to Rule 248(b). Before
acting on respondent's motion, we here decide the motion by
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