T.C. Memo. 1997-317 UNITED STATES TAX COURT MICHAEL M. BRENNAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10985-96. Filed July 9, 1997. Michael M. Brennan, pro se. Elizabeth A. Owen, for respondent. MEMORANDUM OPINION PARR, Judge: This case is before us on respondent's motion for summary judgment under Rule 121.1 Respondent determined a 1 All section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. All dollar amounts are rounded to the (continued...)Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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