T.C. Memo. 2003-95
UNITED STATES TAX COURT
COLOR ARTS, INC., JOHN P. CSEPELLA, A PERSON OTHER THAN THE TAX
MATTERS PERSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5619-00. Filed March 31, 2003.
Jeffrey R. Brodek, for petitioner.
J. Paul Knap, for respondent.
MEMORANDUM OPINION
RUWE, Judge: This case is before the Court fully stipulated
under Rule 122.1 The stipulation of facts, supplemental
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
year at issue.
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