T.C. Memo. 1997-358
UNITED STATES TAX COURT
JOYCE M. AND THOMAS J. HAMM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2400-96. Filed August 5, 1997.
Joyce M. Hamm and Thomas J. Hamm, pro sese.
Amy A. Campbell, for respondent.
MEMORANDUM OPINION
WELLS, Judge: This case is before the Court on respondent's
motion for summary judgment pursuant to Rule 121(a).1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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