T.C. Memo. 2002-26
UNITED STATES TAX COURT
HARLEY GUNDERSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16050-99L. Filed January 25, 2002.
Harley Gunderson, pro se.
Marty J. Dama, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion under Rule 120,1 which, pursuant to Rule
120(b), the Court shall treat as respondent’s motion for summary
judgment under Rule 121.
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
year in issue.
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