T.C. Memo. 2001-123
UNITED STATES TAX COURT
MARTIN H. TONN AND LORRAINE A. TONN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11076-99. Filed May 24, 2001.
Martin H. Tonn and Lorraine A. Tonn, pro sese.
Eric W. Johnson, for respondent.
MEMORANDUM OPINION
RUWE, Judge: This matter is before the Court on
respondent’s motion for partial summary judgment filed pursuant
to Rule 121.1 The issues presented are: (1) Whether the amounts
1Unless 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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