-10-
By setting forth specific facts, petitioners have shown
there is a genuine issue of material fact as to whether the
deductions disallowed by the notice of deficiency should be
allowed. See Rule 121(d). We shall, therefore, deny
respondent’s motion for summary judgment and remand the case to
respondent’s Appeals Office for further proceedings consistent
with this Opinion.
To reflect the foregoing,
An appropriate order will
be issued.
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Last modified: November 10, 2007