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MATUT v. COMMISSIONER

Docket No. 32639-84.

86 T.C. 686 (1986)

ALBERT MATUT AS POSSESSOR OF CERTAIN CASH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 15, 1986.

Attorney(s) appearing for the Case

Michael J. Osman, for the petitioner.

Michael B. Axman, for the respondent.

OPINION

WHITAKER, Judge:

The matter before the Court is respondent's motion for summary judgment filed August 7, 1985, but the issue which we are required to decide is the interpretation of section 6867,1 added to the Code by the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324. In an opinion filed on May 2, 1985, 84 T.C. 803

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