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PRABEL v. COMMISSIONER

Docket No. 8389-87.

91 T.C. 1101 (1988)

BRUCE A. PRABEL AND MARIANNE S. PRABEL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 29, 1988.

Attorney(s) appearing for the Case

John A. Craig and Robert D. Whoriskey, for the petitioners.1

Alan E. Cobb, for the respondent.

OPINION

SWIFT, Judge:

This matter is before the Court on the parties' cross-motions for summary judgment filed under Rule 121.2 Each party objects to the other party's motion on the merits. Petitioners further object to respondent's motion for summary judgment on the ground that there remain unresolved material issues of fact that would have to be decided before respondent's motion for summary judgment can be granted....

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