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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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