Bruce P. Cadwell - Page 1

                                 T.C. Memo. 1995-541                                  


                               UNITED STATES TAX COURT                                


                           BRUCE P. CADWELL, Petitioner v.                            
                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 17703-94.             Filed November 15, 1995.              

               Steven B. Jacobs, for petitioner.                                      
               Kevin G. Croke, for respondent.                                        


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               PARR, Judge:  This case is presently before the Court on               
          respondent's Motion for Summary Judgment pursuant to Rule 121 of            
          the Tax Court Rules of Practice and Procedure;1 the motion was              
          filed October 23, 1995.                                                     


          1                                                                           
               All Rule references are to the Tax Court Rules of Practice             
          and Procedure, and all section references are to the Internal               
          Revenue Code in effect for the taxable years in issue, unless               
          otherwise indicated.                                                        




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