T.C. Memo. 2005-138
UNITED STATES TAX COURT
LAW OFFICES OF MICHAEL B. L. HEPPS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20436-03. Filed June 13, 2005.
Michael Barry Loui Hepps, for petitioner.
James B. Urie, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion for judgment on the pleadings under Rule
120(a) (motion).1 Because petitioner attached exhibits to its
response to respondent’s motion that require us to consider
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the years in issue.
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