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STRONG v. COMMISSIONER

Docket Nos. 821-01, 2048-01.

85 T.C.M. 1063 (2003)

T.C. Memo. 2003-87

Timothy Dean Strong v. Commissioner. Strong Construction Company, Inc., A Minnesota Corporation v. Commissioner.

United States Tax Court.

Filed March 25, 2003.

Attorney(s) appearing for the Case

Thomas E. Brever, for the petitioners.

John C. Schmittdiel and Helen H. Keuning, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge.

These cases are before the Court on petitioners' motion in each docket for partial summary judgment, filed pursuant to Rule 121.1 Respondent filed an objection to the motion in each docket. Petitioners contend that there is no material issue of fact and that they are entitled to partial summary judgment as a matter of law. In particular, petitioners seek to preclude respondent...

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