T.C. Memo. 1996-77
UNITED STATES TAX COURT
EUGENE C. JOSEPH, SR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7574-95. Filed February 26, 1996.
Eugene C. Joseph, Sr., pro se.
John T. Lortie, for respondent.
MEMORANDUM OPINION
PARR, Judge: This case is presently before the Court on
respondent's motion for partial summary judgment filed December
11, 1995, pursuant to Rule 121.1
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 year in issue,
unless otherwise indicated.
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