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CRISTIANO v. COMMISSIONER

Docket No. 18821-90.

67 T.C.M. 2121 (1994)

T.C. Memo. 1994-47

Franklin Joseph Cristiano v. Commissioner.

United States Tax Court.

Filed February 7, 1994.

Attorney(s) appearing for the Case

Franklin Joseph Cristiano, pro se. Mary E. Pierce, for the respondent.

Memorandum Opinion

LARO, Judge:

Respondent moves pursuant to Rule 1211 for an order granting partial summary judgment in her favor on the issues of whether petitioner is taxable on certain unreported gross receipts and whether petitioner is liable for additions to tax under section 6653(b) for his 1979, 1980, and 1981 taxable years. Respondent contends that there is no issue of material fact to be resolved, and, accordingly,...

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