T.C. Memo. 2002-230
UNITED STATES TAX COURT
ROWLAND G. AND VALERIE J. PILARIA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7788-01. Filed September 16, 2002.
John W. Ambrecht and Gregory Arnold, for petitioners.
Elaine T. Fuller, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on petitioners’ motion for partial summary judgment
pursuant to Rule 121(a).1 Petitioners contend that there is no
1 Rule references are to the Tax Court Rules of Practice
and Procedure. Unless otherwise indicated, section references
are to the Internal Revenue Code as amended and in effect during
the year in issue.
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