OPINION
DAWSON, Judge:
On July 19, 1974, petitioners filed a motion for a summary judgment or, alternatively, for a partial summary judgment under Rule 121, Tax Court Rules of Practice and Procedure. On August 30, 1974, respondent filed a memorandum brief opposing petitioners' motion, and on September 11, 1974, petitioners filed a memorandum brief in reply to respondent.
The issue raised by the pleadings in this case is whether petitioner...
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