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TEMPEL v. COMMISSIONER

Docket No. 23689-08.

136 T.C. 341 (2011)

GEORGE H. TEMPEL AND GEORGETTA TEMPEL, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 5, 2011.

Attorney(s) appearing for the Case

James R. Walker and Christopher D. Freeman, for petitioners.

Tamara L. Kotzker and Sara J. Barkley, for respondent.

OPINION

WHERRY, Judge:

This case involves a petition for redetermination of income tax deficiencies determined by respondent for petitioners' 2004 and 2005 tax years. It is before the Court on respondent's August 3, 2009, motion for partial summary judgment and petitioners' August 31, 2009, cross-motion for partial summary judgment. See Rule 121(a).1 Respondent argues that petitioners...

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