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partial summary judgment (respondent’s motion).2 We shall deny
petitioner’s motion, we shall grant respondent’s motion, and we
shall, sua sponte, grant summary judgment for respondent on the
second of the two issues raised in petitioner’s motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Alexandria, Virginia, at the time she
filed the petition in this case.
Petitioner and her former husband, Thomas Martin Seaman (Mr.
Seaman), married on or about April 26, 1960.
During 1964, petitioner purchased a life insurance policy
(Prudential policy) on her life from The Prudential Insurance
Company of America (Prudential) that was in force at least
throughout 2003, the year at issue in this case. The Prudential
policy provides in pertinent part:
1(...continued)
on two issues and notes that respondent concedes a third issue.
See infra note 2.
2In respondent’s motion, respondent seeks summary judgment
on the first, but not the second, of the two issues raised in
petitioner’s motion and concedes a third issue arising from one
of the determinations that respondent made in the notice of
deficiency (notice) that respondent issued to petitioner for her
taxable year 2003. Thus, that third issue is resolved by respon-
dent’s concession, and not by summary adjudication by the Court.
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