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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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