Memorandum Opinion
SWIFT, Judge:
This matter is before the Court under Rule 121 on petitioners' motion for summary judgment and on respondent's cross-motion for partial summary judgment.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code as in effect for 1982.
At the time the petition was filed, petitioners resided in Sands Point...
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