T.C. Memo. 2000-69
UNITED STATES TAX COURT
FALSTONE, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2206-88. Filed March 2, 2000.
Michael D. Savage, for petitioner.
Michael H. Salama and Patrick W. Lucas, for respondent.
MEMORANDUM OPINION
WELLS, Judge: The instant case is before us on cross-
motions for partial summary judgment pursuant to Rule 121(a).1
The issue to be decided is whether, during the years in issue,
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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