T.C. Memo. 2000-320
UNITED STATES TAX COURT
ROBERT C. MacELVAIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16631-99L. Filed October 13, 2000.
Robert C. MacElvain, pro se.
John F. Driscoll and Kerry Bryan, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion for Partial Summary Judgment, filed
pursuant to Rule 121.1 As explained below, we shall grant
respondent's motion.
1 All Rule references are to the Tax Court Rules of
Practice and Procedure, and all section references are to
sections of the Internal Revenue Code, as amended.
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