T.C. Memo. 1999-308
UNITED STATES TAX COURT
AGAPITO FAJARDO AND CLARA S. FAJARDO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11960-97. Filed September 16, 1999.
Agapito Fajardo, pro se.
Michael H. Salama, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This case is before the Court on
respondent's motion for summary judgment filed pursuant to Rule
121.1
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. For convenience, all
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