MEMORANDUM OPINION
CHIECHI, Judge:
This case is before the Court on respondent's motion for summary judgment (respondent's motion). We shall grant respondent's motion.
Background
The record establishes and/or the parties do not dispute the following.
Petitioners resided in Catonsville, Maryland, at the time they filed the petition in this case.
On or about April 15, 2001, petitioners jointly filed a Federal income...
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