Merrill v. Commissioner

JOSEPH S. AND YVONNE Y. MERRILL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Merrill v. Commissioner

Docket No. 8956-89

United States Tax Court

T.C. Memo 1989-590; 1989 Tax Ct. Memo LEXIS 584; 58 T.C.M. (CCH) 558; T.C.M. (RIA) 89590;

October 30, 1989

Calder L. Robertson, Jr., for the respondent.

GUSSIS

MEMORANDUM OPINION

GUSSIS, 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 June 12, 1989. See Rule 40. 1 On July 24, 1989, petitioners filed their opposition to respondent's motion.…