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PERDUE v. COMMISSIONER

Docket No. 16371-98.

79 T.C.M. 1415 (2000)

T.C. Memo. 2000-28

Matthew M. Perdue v. Commissioner.

United States Tax Court.

Filed January 21, 2000.

Attorney(s) appearing for the Case

Rex B. Cruse, Jr., for the petitioner. Gerald L. Brantley, and Dan Cassano, for the respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on petitioner's motion for partial summary judgment, filed pursuant to Rule 121.1 As discussed in detail below, we will deny petitioner's motion.

Background2

On July 9, 1998, respondent issued a notice of deficiency to petitioner determining deficiencies in and additions to his Federal...

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