14
Commissioner, supra at 806-808; Levy v. Commissioner, T.C. Memo.
1987-609, affd. without published opinion 884 F.2d 574 (5th Cir.
1989).
D. Conclusion
We conclude that the notice of deficiency issued in this
case is valid. For the reasons stated above, we deny
petitioners' motion for summary judgment.
An order will be issued
denying petitioners' motion
for summary judgment.
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