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.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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