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STEINBERG v. COMMISSIONER

Docket No. 14135-05L.

92 T.C.M. 340 (2006)

T.C. Memo. 2006-217

Irving and Elaine Steinberg, v. Commissioner.

United States Tax Court.

October 16, 2006.

Attorney(s) appearing for the Case

Gerald W. Kelly, Barry H. Cantor, and Cheryl R. Frank, for petitioners;

Derek W. Kaczmarek, for respondent.

MEMORANDUM OPINION

SWIFT, Judge:

This matter is before us under Rule 121 on respondent's motion for summary judgment.

Unless otherwise indicated, all 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.

Background

At the time the petition was filed, petitioners resided in Las Vegas, Nevada.

For 1990, 1991...

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