T.C. Summary Opinion 2006-137
UNITED STATES TAX COURT
DALE KINSLOW, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1684-05S. Filed August 30, 2006.
Dale Kinslow, pro se.
Trent D. Usitalo, for respondent.
GOLDBERG, Special Trial Judge: This case was heard pursuant
to the provisions of section 7463 of the Internal Revenue Code in
effect at the time the petition was filed. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority.
This matter is before the Court on respondent’s Motion for
Summary Judgment filed pursuant to Rule 121, Tax Court Rules of
Practice and Procedure. In his motion, respondent moves for
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