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SMITH v. COMMISSIONER

Docket No. 11902-05.

92 T.C.M. 219 (2006)

T.C. Memo. 2006-187

Rhett Rance Smith and Alice Avila Smith v. Commissioner.

United States Tax Court.

August 31, 2006.

Attorney(s) appearing for the Case

Robert J. Stientjes, for petitioners.

Anne W. Durning and Henry N. Carriger, for respondent.

MEMORANDUM OPINION

GERBER, Judge:

Petitioners, in a motion filed March 13, 2006, sought the entry of a decision in accord with a purported settlement of this case.1 Respondent, by means of a notice filed April 5, 2006, objected, and the parties presented their views in documents, the last of which was filed July 3, 2006. The question presented by the parties' controversy is whether...

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