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v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.
Commissioner, 79 T.C. 340, 344 (1982).
As explained in more detail below, we agree with the parties
that the issue before us is ripe for summary adjudication.
The following is a summary of the relevant facts that do not
appear to be in dispute. They are stated solely for purposes of
deciding the pending motions and are not findings of fact for
this case. Fed. R. Civ. P. 52(a); Sundstrand Corp. v.
Commissioner, supra at 520.
Background
Stanley B. and Rose M. Whitten (petitioners) are husband
and wife who filed a joint Federal income tax return for 1991.
At the time that their petition was filed in this case,
petitioners resided in Northbrook, Illinois.
Stanley B. Whitten (petitioner) is a criminal investigator
with the United States Securities and Exchange Commission. He is
also a nationally recognized cruciverbalist who has constructed
crossword puzzles that have appeared in newspapers and magazines
throughout the United States, including the Chicago Tribune, the
New York Times, and the Washington Post.
In early 1990, petitioner learned that the staff of the
"Wheel of Fortune" television game show was coming to Chicago,
Illinois, to interview and select contestants to appear on the
program. Petitioner applied for and received an invitation to
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