T.C. Memo. 1995-568
UNITED STATES TAX COURT
MARCIA TYRRELL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10683-91. Filed November 28, 1995.
Marcia Tyrrell, pro se.
Helen F. Rogers, for respondent.
MEMORANDUM OPINION
HAMBLEN, Chief Judge: This matter is before the Court on
respondent's motion for summary judgment pursuant to Rule 121.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the taxable years at issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure. Respondent's motion is based on facts deemed
admitted pursuant to Rule 90(c). Petitioner failed to oppose or
object to respondent's motion.
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