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BERRY v. COMMISSIONER

Docket No. 2387-00.

80 T.C.M. 825 (2000)

T.C. Memo. 2000-373

Thomas D. Berry v. Commissioner.

United States Tax Court.

Filed December 11, 2000.

Attorney(s) appearing for the Case

Kenneth W. Klingenberg, Oklahoma City, Oklahoma, for the petitioner. Donald E. Edwards and Keith Aqui, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is before the Court on the parties' cross Motions for Partial Summary Judgment under Rule 121 (a).1 As explained in detail below, we shall grant respondent's motion and we shall deny petitioner's motion.

Background2

Petitioner resided in Stillwater, Oklahoma, at the...

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