Pebley v. Commissioner
United States Tax Court
Held: All grounds for redetermination set forth in the amended petition are either insufficient, as a matter of law, to form the basis for a redetermination of the deficiency set forth in the statutory notice or, if legally sufficient on their face, are rendered insufficient by the uncontroverted facts. Accordingly, respondent's motion for summary judgment pursuant to Rule 121 is granted.
1Opinion of the Court
BILL W. AND AURIL M. PEBLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pebley v. Commissioner
Docket No. 16726-80.
United States Tax Court
T.C. Memo 1981-701; 1981 Tax Ct. Memo LEXIS 40; 43 T.C.M. (CCH) 71; T.C.M. (RIA) 81701;
December 10, 1981.
Held: All grounds for redetermination set forth in the amended petition are either insufficient, as a matter of law, to form the basis for a redetermination of the deficiency set forth in the statutory notice or, if legally sufficient on their face, are rendered insufficient by the uncontroverted facts. Accordingly, respondent's motion for…
2Cases cited5 opinions
- McCoy v. CommissionerUnited States Tax Court · 1981
- John Factor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Goldsmith v. CommissionerUnited States Tax Court · 1958
- Klein v. CommissionerUnited States Tax Court · 1965
- Voelker v. CommissionerUnited States Tax Court · 1981
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