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...)Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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