OPINION
DAWSON, Chief Judge:
This matter is before the Court on petitioners' Motion for Summary Judgment filed October 15, 1976, pursuant to the provisions of Rule 121, Tax Court Rules of Practice and Procedure. Since the pleadings show that there is no genuine issue as to any material fact, we may render a decision on the merits as a matter of law with respect to the issues presented.
On October 28, 1976, the Court granted a motion by the...
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