T.C. Memo. 2007-345
UNITED STATES TAX COURT
ZELLARD AND CHERYL D. LEMON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8412-04. Filed November 21, 2007.
Larry D. Harvey, for petitioners.
Randall L. Preheim, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for summary judgment pursuant to Rule 121.1
1 Unless otherwise indicated, all 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 in issue.
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