T.C. Memo. 2001-238
UNITED STATES TAX COURT
ROBERT K. AND DAWN E. LOWRY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11579-00. Filed September 14, 2001.
Daniel C. Ertel, for petitioners.
Michael A. Menillo, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on the parties' cross-motions for partial summary
judgment under Rule 121. Unless otherwise indicated, section
references are to the Internal Revenue Code, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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