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.Page: 1 2 3 4 5 6 7 8 Next
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