T.C. Memo. 2003-40
UNITED STATES TAX COURT
WILLIAM G. KOENIG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10236-02L. Filed February 24, 2003.
William G. Koenig, pro se.
Wendy S. Harris and Glenn Thomas, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s Motion For Summary Judgment And To Impose A
Penalty Under I.R.C. Section 6673, filed pursuant to Rule 121.1
Respondent contends that there is no dispute as to any material
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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