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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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