T.C. Memo. 1999-157
UNITED STATES TAX COURT
MARK AND VALORIE KRUSE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15352-95. Filed May 7, 1999.
Steven J. Chase, John W. West III, Cheryl L. Gordon, and
Dale S. Davidson, for petitioners.
Randall B. Pooler and Randall P. Andreozzi, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent's Motion for Summary Judgment pursuant to
Rule 121.1 The issue for decision is whether there is a genuine
1
All Rule references are to the Tax Court Rules of
Practice and Procedure. All section references are to the
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