ROBERTS v. COMMISSIONER

Docket No. 1991-01L.

118 T.C. 365 (2002)

118 T.C. No. 23

THOMAS W. ROBERTS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 3, 2002.


Attorney(s) appearing for the Case

Thomas W. Roberts, pro se.

Joanne B. Minsky, for respondent.


OPINION

CHIECHI, Judge:

This case is before the Court on the parties' cross-motions for partial summary judgment.1 We shall deny petitioner's motion for partial summary judgment (petitioner's motion), and we shall grant respondent's motion for partial summary judgment (respondent's motion).

Background

The record establishes and/or the parties do not dispute the following.

Petitioner resided...

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