George M. Osserman - Page 18

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          on this issue.  We shall grant respondent's motion for partial              
          summary judgment with respect to a finding that the notices of              
          deficiency herein were timely mailed to petitioner and that                 
          assessment is not time barred.  Secs. 6213, 6501(c); see                    
          Alexander v. Commissioner, T.C. Memo. 1990-315.                             
               We shall grant respondent's Motion for Partial Summary                 
          Judgment with respect to all of the issues raised therein, except           
          the issue of other or miscellaneous income determined for taxable           
          years 1976, 1977, and 1978.                                                 
               In order to reflect the foregoing,                                     

                                             An appropriate order will be             
                                        issued granting respondent's Motion           
                                        for Partial Summary Judgment in               
                                             part and denying her motion in           
                                             part.                                    




















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