MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion for summary judgment.
Background
None of the facts have been stipulated. At the time he filed the petition, petitioner resided in Las Vegas, Nevada.
Petitioner submitted Forms 1040, U.S. Individual Income Tax Return, for 1999 and 2000 to respondent. Petitioner listed zero as the amount of his wages, total income, adjusted gross income...
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