T.C. Memo. 2001-283
UNITED STATES TAX COURT
WILLIAM RICHARD BAKER, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5596-99. Filed October 12, 2001.
William Richard Baker, Jr., pro se.
Edsel Ford Holman, Jr., for respondent.
MEMORANDUM OPINION
RUWE, Judge: This matter is before this Court on
respondent’s motion for partial summary judgment, which was filed
pursuant to Rule 121.1 The issues for decision are whether
1Unless 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
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