T.C. Memo. 2000-373
UNITED STATES TAX COURT
THOMAS D. BERRY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2387-00. Filed December 11, 2000.
Kenneth W. Klingenberg, for petitioner.
Donald E. Edwards and Keith Aqui, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on the parties’ cross Motions for Partial Summary Judgment under
Rule 121(a).1 As explained in detail below, we shall grant
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure and all section
references are to the Internal Revenue Code in effect for 1996,
the taxable year in issue.
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