T.C. Memo. 2005-170
UNITED STATES TAX COURT
ROBERT H. GOLDEN AND JUDITH A. GOLDEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16694-04L. Filed July 11, 2005.
Robert H. Golden and Judith A. Golden, pro sese.
A. Gary Begun, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case is before the Court on
respondent’s motion for partial summary judgment filed pursuant
to Rule 121. All Rule references are to the Tax Court Rules of
Practice and Procedure. All section references are to the
Internal Revenue Code of 1986, as amended.
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