Opinion
21015-19
01-26-2023
ORDER
Kathleen Kerrigan Chief Judge
Pursuant to the findings of the Court as set forth in Treece Investment. Advisory Corp. v. Commissioner, T.C. Memo 2022-38, filed April 19, 2022, it is hereby
ORDERED that respondent's motion for partial summary judgment, filed October 19, 2021, is denied. It is further
ORDERED that petitioner's motion for summary judgment, filed October 20, 2021, is denied.