T.C. Memo. 2002-86
UNITED STATES TAX COURT
EMIL P. TOLOTTI, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3011-01L. Filed April 1, 2002.
Emil P. Tolotti, Jr., pro se.
Sheara L. Gelman, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion for Summary Judgment, as supplemented,
filed pursuant to Rule 121(a).1 Respondent contends that there
is no dispute as to any material fact with respect to this
1 All Rule references are to the Tax Court Rules of
Practice and Procedure. Unless otherwise indicated, all section
references are to the Internal Revenue Code, as amended.
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