T.C. Memo. 2002-63
UNITED STATES TAX COURT
ROBERT E. MCKELVEY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1971-00. Filed March 5, 2002.
Robert E. McKelvey, pro se.
Daniel J. Parent, for respondent.
MEMORANDUM OPINION
BEGHE, Judge: This case is before the Court under Rule 1211
on petitioner’s motion for summary judgment and respondent’s
cross-motion for summary judgment.
1All 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 years in issue, unless otherwise
indicated.
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