T.C. Memo. 2003-264
UNITED STATES TAX COURT
JOHN J. GREEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13977-01L. Filed September 10, 2003.
Jerry Arthur Jewett, for petitioner.
Robert T. Little, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This case is before the Court on
respondent’s motion for summary judgment filed pursuant to Rule
121 .1
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure. Amounts are rounded to
the nearest dollar.
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