T.C. Memo. 2000-258
UNITED STATES TAX COURT
PATRICIA R. CARPENTIER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2430-96. Filed August 16, 2000.
Douglas D. Potratz, for petitioner.
Ralph W. Jones, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion for Summary Judgment filed pursuant to
Rule 121(a).1 As explained in detail below, we will grant
1 All Rule references to the Tax Court Rules of Practice
and Procedure.
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