T.C. Memo. 1999-89
UNITED STATES TAX COURT
LINDA RUTH PALMER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9338-97. Filed March 23, 1999.
Clinton M. Fried and Kirk S. Chaberski, for respondent.
MEMORANDUM OPINION
WELLS, Judge: This case is before the Court on respondent's
motion for summary judgment pursuant to Rule 121. Unless
otherwise indicated all section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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