T.C. Memo. 2003-17
UNITED STATES TAX COURT
JAN LISTER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9173-02L. Filed January 21, 2003.
Jan Lister, pro se.
Donald E. Edwards, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion for summary judgment, filed pursuant to Rule
121, and to impose a penalty under section 6673.1 Respondent
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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