T.C. Memo. 1997-345
UNITED STATES TAX COURT
JOSEPH J. AND LILLIAN A. GAJDA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2210-97. Filed July 28, 1997.
Leonard L. Leighton, for petitioners.
Elizabeth A. Owen, for respondent.
MEMORANDUM OPINION
PARR, Judge: This case is before us on respondent's motion
for summary judgment under Rule 121.1 Respondent determined a
1 All section references are to the Internal Revenue Code in
effect for the taxable year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure, unless
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