OPINION
NIMS, Judge:
This matter is before the Court on the following three motions: (1) Petitioners' motion for leave to file amendment to petition pursuant to Rule 41(a); (2) respondent's motion for leave to file amendment to answer pursuant to Rule 41(a); and (3) petitioners' motion for summary judgment filed pursuant to Rule 121.
Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for...
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