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SHEPHERD v. COMMISSIONER

Docket No. 23963-96.

74 T.C.M. 1404 (1997)

T.C. Memo. 1997-555

Lloyd D. Shepherd v. Commissioner.

United States Tax Court.

Filed December 22, 1997.

Attorney(s) appearing for the Case

Timothy Patrick Assaf, for the petitioner. Russell D. Pinkerton and Peter Reilly, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is before the Court on respondent's Motion for Summary Judgment filed pursuant to Rule 121.1 As explained in greater detail below, we will grant respondent's motion.

Background

Respondent issued a notice of deficiency to Lloyd D. Shepherd (petitioner) determining deficiencies in and additions to his Federal income taxes for the taxable years and...

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