T.C. Memo. 2005-142
UNITED STATES TAX COURT
JULIAN W. MANDODY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8822-03L. Filed June 20, 2005.
Julian W. Mandody, pro se.
Francis C. Mucciolo, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for summary judgment.
Rule 121(a)1 provides that either party may move for summary
judgment upon all or any part of the legal issues in controversy.
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.
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