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THORNOCK v. COMMISSIONER

Docket No. 29123-86.

94 T.C. 439 (1990)

RUSSELL D. THORNOCK AND CATHY A. THORNOCK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 19, 1990.

Attorney(s) appearing for the Case

Stephen E. Silver, Brad S. Ostroff, and Stephen D. Gardner, for the petitioners.

Theodore J. Kletnick and Sandy E. Freund, for the respondent.

OPINION

SWIFT, Judge:

This matter is before the Court on the parties' cross-motions for partial summary judgment. Rule 121(b). The motions raise essentially legal issues or issues of ultimate fact that the parties ask us to resolve, in the context of these motions, solely on the basis of the relevant undisputed stipulated facts, documents, and applicable law. This is a test case that will affect the outcome...

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