T.C. Memo. 2002-87
UNITED STATES TAX COURT
STEPHEN AND PATRICIA LINDSEY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9014-00L. Filed April 2, 2002.
Stephen and Patricia Lindsey, pro sese.
Kerry H. Bryan, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion for Summary Judgment, as supplemented,
filed pursuant to Rule 121(a).1 Respondent contends that there
is no genuine issue as to any material fact and that respondent’s
1 All Rule references are to the Tax Court Rules of
Practice and Procedure. Unless otherwise indicated, all section
references are to the Internal Revenue Code, as amended.
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