Memorandum Findings of Fact and Opinion
PAJAK, Special Trial Judge:
All section numbers refer to the Internal Revenue Code for the taxable year in issue, and all Rule numbers refer to the Tax Court Rules of Practice and Procedure.
This case is before the Court on respondent's motion for partial summary judgment and petitioners' cross-motion for summary judgment under Rule 121. The issue we must decide is whether the statute of limitations under section...
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