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SEAMAN v. COMMISSIONER

Docket No. 22048-05.

94 T.C.M. 58 (2007)

T.C. Memo. 2007-189

Barbara E. Seaman v. Commissioner.

United States Tax Court.

Filed July 16, 2007.

Attorney(s) appearing for the Case

Barbara E. Seaman, pro se.

Sandra M. Jefferson, for respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

This case is before the Court on petitioner's motion for summary judgment that the Court has recharacterized as petitioner's motion for partial summary judgment (petitioner's motion)1 and respondent's cross-motion for partial summary judgment (respondent's motion).2 We shall deny petitioner's motion, we shall grant respondent's motion, and we shall, sua sponte, grant...

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