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Clifford W. Miller, pro se.
William L. Blagg, for respondent.
OPINION
CHIECHI, Judge: This case is before the Court on respon-
dent’s motion for judgment on the pleadings which was filed on
June 12, 2000, and which, pursuant to Rule 120(b),1 the Court
shall treat as respondent's motion for summary judgment under
Rule 121 (respondent’s motion). On July 10, 2000, petitioner
filed a response to respondent’s motion, and on August 1, 2000,
respondent filed a reply to petitioner’s response. On September
11, 2000, the Court held a hearing on respondent’s motion. As
directed by the Court, respondent filed a supplement to respon-
dent’s motion on October 2, 2000, in which respondent provided
additional information regarding that motion. On October 24,
2000, petitioner filed a response to respondent’s supplement.
Background
In the various filings by the parties with respect to
respondent’s motion, the parties do not dispute the following
facts.
1All Rule references are to the Tax Court Rules of Practice
and Procedure. All section references are to the Internal
Revenue Code (Code) in effect at the times indicated.
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Last modified: May 25, 2011