T.C. Memo. 2004-168
UNITED STATES TAX COURT
PEGGY A. FARLEY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6897-03L. Filed July 19, 2004.
Peggy A. Farley, pro se.
Brian D. Derdowski, 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 As explained in more detail below we
shall grant such motion.
1 Section references are to the Internal Revenue Code, as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure.
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