T.C. Memo. 2006-220
UNITED STATES TAX COURT
NELSON I. AND ESTHER S. GOODMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21917-04L. Filed October 23, 2006.
Martin D. Tropper, for petitioners.
Alex Shlivko, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case is before the Court
on respondent's motion for summary judgment filed pursuant to
Rule 121. Rule references are to the Tax Court Rules of Practice
and Procedure. Section references are to the Internal Revenue
Code of 1986 as amended. The motion arises in the context of a
petition filed in response to a Notice of Determination
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