T.C. Memo. 1997-342
UNITED STATES TAX COURT
WILLIAM ROGER AND JOAN ANN THORPE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14305-96. Filed July 28, 1997.
William Roger Thorpe and Joan Ann Thorpe, pro sese.
Elizabeth A. Owen and Carol P. Nachman, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This case is before the Court
on respondent's motion for partial summary judgment, filed
pursuant to Rule 121.1 The issue for decision is whether
1 Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
(continued...)
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