T.C. Memo. 1999-422
UNITED STATES TAX COURT
WILLIAM J. TULLY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16008-98. Filed December 27, 1999.
William J. Tully, pro se.
Edwin A. Herrera, for respondent.
MEMORANDUM OPINION
WELLS, Judge: This case is before the Court on respondent's
motion for partial summary judgment and second motion for partial
summary judgment pursuant to Rule 121.1 Respondent determined a
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code as in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
(continued...)
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