T.C. Memo. 2001-305
UNITED STATES TAX COURT
BARRY L. MOORE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11675-00L. Filed November 27, 2001.
E. Kenneth Wall, for petitioner.
Taylor Cortright, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion for Partial Summary Judgment, as
supplemented, filed pursuant to Rule 121.1 Respondent contends
1 All Rule references are to the Tax Court Rules of
Practice and Procedure, and all section references are to the
Internal Revenue Code, as amended.
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