Memorandum Opinion
SWIFT, Judge:
This matter is before the Court on petitioner's motion for summary judgment under Rule 121 of the Tax Court Rules of Practice and Procedure. All of the facts relevant to this motion have been stipulated by the parties and are incorporated herein by reference. The issue is therefore ripe for resolution by way of summary judgment.
At the time of filing his petition herein, petitioner resided in Acton, Massachusetts...
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