T.C. Memo. 2007-304
UNITED STATES TAX COURT
ALFRED A. DIFFEE, JR. AND NORMA J. DIFFEE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16567-06. Filed October 9, 2007.
Paul R. Tom, for petitioners.
G. Chad Barton, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion for summary judgment, filed under Rule 121.1
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the years at issue. Some monetary
amounts are rounded to the nearest dollar.
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Last modified: November 10, 2007