MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. This matter is before the Court on Respondent's 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...
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