T.C. Memo. 2001-65
UNITED STATES TAX COURT
ALAN R. WYLIE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6949-00L. Filed March 20, 2001.
Thomas W. Roberts, for petitioner.
Karen Nicholson Sommers, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is based on a petition filed under
section 6330(d).1 Respondent moved for summary judgment under
Rule 121(a) on November 6, 2000. The Court, by order dated
November 8, 2000, required petitioner to respond to respondent’s
1Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
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