T.C. Memo. 1997-440
UNITED STATES TAX COURT
FREDERICK M. FOX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24822-95. Filed September 25, 1997.
Frederick M. Fox, pro se.
Christine V. Olsen, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
respondent's motion for summary judgment under Rule 121.1 As
discussed below, we will grant respondent's motion. We will also
1Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code
as in effect for the years in issue.
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