T.C. Memo. 2005-226
UNITED STATES TAX COURT
KEITH D. HILEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21768-03. Filed September 29, 2005.
Brian G. Isaacson and Duncan C. Turner, for petitioner.
Sandra Veliz, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This case is before the Court on the
parties’ cross-motions for summary judgment pursuant to Rule
121.1 The issue for decision is whether petitioner received
1 Unless otherwise indicated, Rule references are to the
Tax Court Rules of Practice and Procedure, and section references
are to the Internal Revenue Code, as amended. Amounts are
rounded to the nearest dollar.
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