T.C. Memo. 1996-292
UNITED STATES TAX COURT
GALEN J. SMITH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8945-95. Filed June 24, 1996.
Galen J. Smith, pro se.
Pamelya P. Herndon, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is before the Court on respondent's
motion for continuance of trial pursuant to Rule 1341 and
petitioner's motion for partial summary judgment under Rule 121.
This case was originally set for trial on April 22, 1996, in
Albuquerque, New Mexico. Ten days before trial, respondent
issued a statutory notice of deficiency to petitioner's former
spouse. At the calendar call, respondent moved the Court to
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years at issue,
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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