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 Waterloo, Iowa, at the time they filed the petition in this case.
Petitioners jointly filed a Federal income tax (tax) return for their taxable...
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