MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case is before us on petitioner's motion for summary judgment and respondent's cross-motion for summary judgment filed pursuant to Rule 121. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent determined a deficiency of $6,092 in petitioner's 1995 Federal...
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