T.C. Memo. 2005-7
UNITED STATES TAX COURT
JOHN F. DALTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16780-03L. Filed January 24, 2005.
John F. Dalton, pro se.
A. Gary Begun, for respondent.
MEMORANDUM OPINION
KROUPA, Judge: This matter is before the Court on
respondent’s Motion for Summary Judgment, filed pursuant to Rule
121(a).1 Respondent contends that there is no dispute as to any
1All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, as amended, unless
otherwise indicated.
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