T.C. Memo. 2002-132
UNITED STATES TAX COURT
SHADE D. COLEMAN III AND MARIA M. COLEMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5995-01L. Filed May 30, 2002.
Shade D. Coleman III and Maria M. Coleman, pro sese.
Karen Baker and Rollin G. Thorley, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s motion for summary judgment pursuant to
Rule 121.1 Respondent contends that there is no dispute as to
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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