T.C. Memo. 2003-87
UNITED STATES TAX COURT
TIMOTHY DEAN STRONG, Petitioner v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
STRONG CONSTRUCTION COMPANY, INC., A MINNESOTA CORPORATION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 821-01, 2048-01. Filed March 25, 2003.
Thomas E. Brever, for petitioners.
John C. Schmittdiel and Helen H. Keuning, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: These cases are before
the Court on petitioners’ motion in each docket for partial
summary judgment, filed pursuant to Rule 121.1 Respondent filed
1 At the hearing on this matter respondent requested that
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