T.C. Memo. 2002-203
UNITED STATES TAX COURT
MICHAEL SCHAPER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3049-02L. Filed August 13, 2002.
Michael Schaper, pro se.
Alan J. Tomsic and Scott A. Hovey, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s Motion For Summary Judgment, filed
pursuant to Rule 121.1 Respondent contends that there is no
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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