Opinion
12718-19
03-22-2022
ORDER
Albert G. Lauber, Judge
Pursuant to the Court's Opinion (T.C. Memo. 2022-23) issued in the above-docketed case on March 21, 2022, it is
ORDERED that petitioner's Motion for Partial Summary Judgment, filed November 9, 2021, is denied. It is further
ORDERED that respondent's Motion for Partial Summary Judgment, filed December 9, 2021, is granted.