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MILLS v. COMMISSIONER

Docket No. 18442-03L.

88 T.C.M. 21 (2004)

T.C. Memo. 2004-164

Kathryn D. Mills, v. Commissioner.

United States Tax Court.

July 13, 2004.

Attorney(s) appearing for the Case

Donald Louis Herskovitz, for petitioner;

Jeffrey E. Gold, for respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

This case is before the Court on respondent's motion for summary judgment (respondent's motion).1 We shall grant respondent's motion.

Background

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

Petitioner resided in Prospect, Connecticut, at the time she filed the petition in this case.

On April 15, 2001, petitioner filed a Federal...

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