T.C. Memo. 2007-316 UNITED STATES TAX COURT MARVIN SILVERMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13629-05L. Filed October 18, 2007. Marvin Silverman, pro se. Gavin L. Greene, 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.Page: 1 2 3 4 5 NextLast modified: November 10, 2007