T.C. Memo. 2004-248
UNITED STATES TAX COURT
RICHARD REWERTS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2545-02L. Filed November 1, 2004.
Richard Rewerts, pro se.
Rebecca S. Duewer-Grenville, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This matter is before us on respondent’s
motion for summary judgment pursuant to Rule 121.1 The issue for
decision is whether there was an abuse of discretion in
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 of 1986, as amended.
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