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STEPHEN v. COMMISSIONER

Docket No. 9014-00L.

83 T.C.M. 1440 (2002)

T.C. Memo. 2002-87

Stephen and Patricia Lindsey v. Commissioner.

United States Tax Court.

Filed April 2, 2002.

Attorney(s) appearing for the Case

Stephen and Patricia Lindsey, pro sese.

Kerry H. Bryan, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge.

This matter is before the Court on respondent's Motion for Summary Judgment, as supplemented, filed pursuant to Rule 121(a).1 Respondent contends that there is no genuine issue as to any material fact and that respondent's notice of determination should be sustained as a matter of law.

Summary judgment is intended to expedite litigation and avoid unnecessary and expensive...

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