T.C. Memo. 1996-355
UNITED STATES TAX COURT
EDWARD A. WAGNER AND
BARBARA WAGNER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7602-88. Filed August 5, 1996.
Jared J. Scharf, for petitioners.
Michael D. Wilder, for respondent.
MEMORANDUM OPINION
BEGHE, Judge: This case is before us on respondent’s motion
for summary judgment under Rule 121(b)1 that petitioner Edward A.
1Except where otherwise noted, rules referred to are the
Rules of this Court, and sections referred to are sections of the
Internal Revenue Code in effect in the year in question.
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