T.C. Memo. 2005-178
UNITED STATES TAX COURT
ROBERT J. MERLO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21538-03. Filed July 20, 2005.
Brian G. Isaacson and Don Paul Badgley, for petitioner.
Sandra Veliz, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This case is before the Court on the
parties’ cross-motions for partial summary judgment pursuant to
Rule 121.1 The issues for decision are: (1) Whether
petitioner’s rights to shares of stock of Exodus Communications,
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.
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