OPINION
DAWSON, Judge:
These two cases are before the Court on petitioners' motions for summary judgment filed March 25, 1977, with respect to docket No. 7461-73, and April 11, 1977, with respect to docket No. 7718-73, pursuant to the provisions of Rule 121, Tax Court Rules of Practice and Procedure. Respondent filed objections to the motions on April 15, 1977, and a hearing was held in Washington, D.C., on April 27, 1977. Petitioners in each docket...
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