T.C. Memo. 2003-37
UNITED STATES TAX COURT
ALLEN CHARLES SCHENKEL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10855-01L. Filed February 20, 2003.
Allen Charles Schenkel, pro se.
Lisa M. Oshiro, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for summary judgment.
Rule 121(a)1 provides that either party may move for summary
judgment upon all or any part of the legal issues in controversy.
Full or partial summary judgment may be granted only if it is
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code.
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