T.C. Memo. 1997-501
UNITED STATES TAX COURT
JOSEPH S. KING, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7532-94. Filed November 6, 1997.
Joseph S. King, pro se.
Margaret A. Martin, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was assigned
pursuant to the provisions of section 7443A(b)(3) and Rules 180,
181, and 182.1 This matter is before the Court on respondent’s
Motion for Summary Judgment pursuant to Rule 121.
1
All section references are to the Internal Revenue Code
in effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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