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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011