T.C. Memo. 1997-555
UNITED STATES TAX COURT
LLOYD D. SHEPHERD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23963-96. Filed December 22, 1997.
Timothy Patrick Assaf, for petitioner.
Russell D. Pinkerton and Peter Reilly, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion for Summary Judgment filed pursuant to
Rule 121.1 As explained in greater detail below, we will grant
respondent's motion.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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