United States Tax Court January 7, 1976, Docket No. 4767-74 (McShain v. Commissioner)

lead-opinion

OPINION

Dawson, Chief Judge:

This matter is before the Court on petitioners’ Motion for Summary Judgment Upon Part of the Legal Issues in Controversy filed on July 25, 1975, pursuant to Rule 121, Tax Court Rules of Practice and Procedure. After the parties filed written statements of their positions, a hearing was held in Washington, D.C., on October 15,1975.