LOREN KIEVE and ANNE H.
KIEVE,
Petitioners
I t
DISTRICT OF COLUMBIA
SUPERIOR COURT OF THE DISTRICT
TAX DIVISION
OF COLUMBIA
r t
*::
--.
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Respondent
MEMORANDW OPINTON AND ORDER
Petitioners herein have filed a Motion for Partial Summary
,Judgment, as...
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LOREN KIEVE and ANNE H.
KIEVE,
Petitioners
I t
DISTRICT OF COLUMBIA
SUPERIOR COURT OF THE DISTRICT
TAX DIVISION
OF COLUMBIA
r t
*::
--.
r | l
Respondent
MEMORANDW OPINTON AND ORDER
Petitioners herein have filed a Motion for Partial Summary
,Judgment, as part of their appeal of income tax assessments for Tax
Years 1991, 1992, and 1993.
The District opposes this Motion, and
counsel submitted additional pleadings following oral arg,ument, as
direct.
ed by the Court.
The key issue raised in the Motion is, as the District
describes it, a "fronEa1 attacktt on the authority of the District
of Columbia Council to enact legislation to eradicate the effects
of an appellate courL ruling Ehat recog:nizes and permits the use of
a certain tax credit.
Petitioners were adversely affected by the
legislation, because they desire to claim this disputed credit in
order to lower their tax liability.
The heart of the Mot.
ion is Petitioners contention that t.
he
legislat.
ion is void because of t.
h
Less
