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, andPage: 1 2 3 4 5 NextLast modified: November 10, 2007