T.C. Memo. 1997-256
UNITED STATES TAX COURT
JOHN DEVLIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7779-94. Filed June 9, 1997.
Randall L. Preheim, for respondent.
MEMORANDUM OPINION
FAY, Judge: This case is before the Court on respondent's
Motion for Summary Judgment pursuant to Rule 121.1 Respondent's
Motion for Summary Judgment was based on matters deemed admitted
by reason of petitioner's failure to respond to two requests for
1All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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