LAW OFFICES OF HEPPS v. COMMISSIONER

Dkt. No. 20436-03.

89 T.C.M. 1429 (2005)

T.C. Memo. 2005-138

Law Offices of Michael B. L. Hepps v. Commissioner.

United States Tax Court.

June 13, 2005.


Attorney(s) appearing for the Case

Michael Barry Loui Hepps, for petitioner.

James B. Urie, for respondent.


MEMORANDUM OPINION

MARVEL, Judge:

This matter is before the Court on respondent's motion for judgment on the pleadings under Rule 120(a) (motion).1 Because petitioner attached exhibits to its response to respondent's motion that require us to consider matters outside the pleadings, we shall treat respondent's motion as a motion for summary judgment under Rule 121. See Rule 120(b).

Summary judgment is a procedure designed...

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