T.C. Memo. 1997-483
UNITED STATES TAX COURT
IRENE EISENBERG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17267-95. Filed October 27, 1997.
Martin A. Stoll, for petitioner.
Drita Tonuzi, for respondent.
MEMORANDUM OPINION
HAMBLEN, Judge: This matter is before the Court on the
parties' cross-motions for summary judgment pursuant to Rule
121.1 Both parties submitted memoranda in support of their
respective positions.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the years at issue,
and Rule references are to the Tax Court Rules of Practice and
Procedure.
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