T.C. Memo. 2007-307 UNITED STATES TAX COURT GARY J. GIAMMATTEO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9220-04. Filed October 10, 2007. Larry D. Harvey, for petitioner. Randall L. Preheim, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: This case is before the Court on respondent’s motion for summary judgment pursuant to Rule 121.1 1 Unless 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 in effect for the years in issue.Page: 1 2 3 4 NextLast modified: November 10, 2007