T.C. Memo. 2000-319
UNITED STATES TAX COURT
WILLIAM W. HOWARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13447-99L. Filed October 13, 2000.
William W. Howard, pro se.
Michael D. Zima and Kerry Bryan, 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(a).1 As explained in detail below, we shall grant
respondent’s motion.
1 All Rule references to the Tax Court Rules of Practice
and Procedure, and unless otherwise indicated, all section
references are to the Internal Revenue Code, as amended.
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