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Yvonne E. Thurner, pro se in docket No. 9971-01.
Scott P. Thurner, pro se in docket No. 3586-02.
James M. Klein, Mark J. Miller, and Charles Hall, for
respondent.
OPINION
COHEN, Judge: This case was assigned to Chief Special Trial
Judge Peter J. Panuthos, pursuant to the provisions of section
7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with
and adopts the opinion of the Chief Special Trial Judge, which is
set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: These consolidated
cases are before the Court on respondent’s Motions for Summary
Judgment, as supplemented, filed pursuant to Rule 121. As
explained in detail below, we shall grant respondent’s Motion for
Summary Judgment, as supplemented, as to petitioner Scott P.
Thurner, and grant respondent partial summary judgment as to
petitioner Yvonne E. Thurner.
1 Section references are to sections of the Internal
Revenue Code, as amended, and Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011