T.C. Memo. 2007-133
UNITED STATES TAX COURT
CHERYL A. WOLF, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3747-04L. Filed May 30, 2007.
Cheryl A. Wolf, pro se.
Marc L. Caine, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This matter is before us on respondent’s Rule
53 motion to partially dismiss for lack of jurisdiction as to one
matter and on respondent’s Rule 121 motion for summary judgment
as to all other matters.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at all relevant times, and
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Last modified: November 10, 2007