T.C. Memo. 2007-348
UNITED STATES TAX COURT
CHARLES R. CUTLER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7590-02. Filed November 26, 2007.
Charles R. Cutler, pro se.
Scott T. Welch, for respondent.
MEMORANDUM OPINION
HAINES, Judge: This case is before the Court on
respondent’s motion for summary judgment filed pursuant to Rule
121.1 Respondent argues that the factual allegations deemed
1All section references are to the Internal Revenue Code, as
amended. Rule references are to the Tax Court Rules of Practice
and Procedure. Amounts are rounded to the nearest dollar.
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