T.C. Memo. 2007-118 UNITED STATES TAX COURT TIMOTHY L. CLOUSE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13119-02L. Filed May 9, 2007. Timothy L. Clouse, pro se. Anita A. Gill, for respondent. MEMORANDUM OPINION WELLS, Judge: This matter is before the Court on respondent’s motion for summary judgment pursuant to Rule 121.1 The issue we must decide is whether respondent may proceed to 1Unless 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, as amended.Page: 1 2 3 4 5 6 NextLast modified: November 10, 2007