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Jensen v. Commissioner

Docket No. 10576-02L.

87 T.C.M. 1340 (2004)

T.C. Memo. 2004-120

James L. Jensen v. Commissioner.

United States Tax Court.

May 17, 2004.

Attorney(s) appearing for the Case

James L. Jensen, pro se.

Stephen P. Baker, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before the Court on respondent's motion for summary judgment and to impose a penalty under section 66731 (motion for summary judgment) and petitioner's motion to strike respondent's motion for summary judgment (motion to strike).

Rule 121(a) provides that either party may move for summary judgment upon all or any part of the legal issues in controversy. Full or partial summary...

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