T.C. Memo. 1997-336
UNITED STATES TAX COURT
JULIUS R. PHILLIPS AND MARCIA G. PHILLIPS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7996-96. Filed July 24, 1997.
Michael Hinchion, for petitioners.
Edsel Ford Holman, Jr., for respondent.
MEMORANDUM OPINION
PARR, Judge: This case is before us on the parties' cross-
motions for summary judgment under Rule 121.1 Respondent
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
otherwise indicated. All dollar amounts are rounded to the
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