T.C. Memo. 1996-12
UNITED STATES TAX COURT
CHARLES AND MARTHA McHAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 550-92. Filed January 22, 1996.
R. Walton Davis III, for petitioner Martha McHan.
Charles McHan, pro se.
Eric B. Jorgensen, for respondent.
MEMORANDUM OPINION
PARR, Judge: This case is presently before the Court on
petitioner Charles McHan's and petitioner Martha McHan's
(hereinafter sometimes referred to as Charles and Martha,
respectively) separately filed motions for summary judgment
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