T.C. Memo. 2005-167
UNITED STATES TAX COURT
RONALD A. AND CAROL J. LEHRER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2381-04. Filed July 11, 2005.
John Gigounas, for petitioners.
Margaret A. Martin, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This case is before the Court on
respondent’s motion for partial summary judgment pursuant to Rule
121.1 The issue for our consideration is whether petitioners
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. Amounts
are rounded to the nearest dollar.
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