Irene Eisenberg - Page 1


                                 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              

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