T.C. Memo. 2006-268
UNITED STATES TAX COURT
STEVEN A. AND PATRICIA A. KNISH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 323-05. Filed December 18, 2006.
Thomas E. Brever and Barbara A. Olson, for petitioners.
David L. Zoss, for respondent.
MEMORANDUM OPINION
KROUPA, Judge: This matter is before the Court on the
parties’ cross-motions for partial summary judgment, both filed
pursuant to Rule 121.1 We are asked to decide whether
petitioners and SPK, petitioners’ wholly owned S corporation,
1All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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