T.C. Memo. 1996-6
UNITED STATES TAX COURT
JOSEPH C. STEPIEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8161-95. Filed January 11, 1996.
Raymond N. McCabe, for petitioner.
Lynne Camillo and Matthew I. Root, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is presently before
the Court on respondent's Motion for Partial Summary Judgment.
Respondent seeks a partial summary adjudication that there
is an underpayment in petitioner's income tax for the taxable
year 1984, and that a portion of such underpayment is
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