T.C. Memo. 2007-241 UNITED STATES TAX COURT BOBBY J. PRATER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22188-06L. Filed August 22, 2007. Paul R. Tom, for petitioner. Elizabeth Downs, for respondent. MEMORANDUM OPINION MARVEL, Judge: This matter is before the Court on respondent’s motion for summary judgment, filed under Rule 121.1 1All 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 at issue.Page: 1 2 3 4 5 6 7 NextLast modified: November 10, 2007