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COX v. COMMISSIONER

Docket No. 30187-91.

66 T.C.M. 192 (1993)

T.C. Memo. 1993-326

D. Sherman and Maxine M. Cox v. Commissioner.

United States Tax Court.

Filed July 22, 1993.

Attorney(s) appearing for the Case

John W. Schwartz, Jr., 210 Cross Keys Center, Flarissant, Mo., for the petitioners. Thomas C. Oswald, for the respondent.

Memorandum Opinion

BUCKLEY, Special Trial Judge:

This matter is assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 1821 for purposes of ruling on respondent's Motion for Partial Summary Judgment and petitioners' Motion for Partial Summary Judgment. Our Rule 121 provides for partial summary judgment as to any issue when it is clear that there is no genuine issue as to any material fact and that...

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