PREECE v. COMMISSIONER

Docket No. 17010-89.

95 T.C. 594 (1990)

DEBRA F. PREECE AND DAVID K. PREECE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 5, 1990.


Attorney(s) appearing for the Case

John A. Townsend, for the petitioners.

James M. Kamman and Christopher D. Hatfield, for the respondent.


OPINION

NIMS, Chief Judge:

This matter is before the Court on petitioners' motion for summary judgment pursuant to Rule 121. (Unless otherwise indicated, section references are to the Internal Revenue Code as amended and in effect for the year at issue. Rule references are to the Tax Court Rules of Practice and Procedure.)

This case involves the question of whether the so-called mirror code of the...

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