T.C. Memo. 1996-233
UNITED STATES TAX COURT
DAVID A. STURMAN AND CELINDA M. STURMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10024-95. Filed May 22, 1996.
F. Richard Losey and Daniel J. Leer, for petitioners.
Debra K. Estrem, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioners move for summary adjudication in
their favor, arguing that res judicata disposes of this case.
Petitioners support their motion with two affidavits (with
attached exhibits), as well as a memorandum of law. Petitioners’
affiants are: (1) David A. Sturman, one of petitioners herein
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