T.C. Memo. 2000-328
UNITED STATES TAX COURT
RONALD J. AND LINDA GABRIEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25660-95. Filed October 20, 2000.
Arthur I. Fixler, for petitioners.
Carmino J. Santaniello, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182. This matter is before the Court on Respondent's
Motion for Summary Judgment filed pursuant to Rule 121. Unless
otherwise indicated, section references are to the Internal
Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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