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COONEY v. COMMISSIONER

Docket No. 20897-92.

67 T.C.M. 2128 (1994)

T.C. Memo. 1994-50

Edward Anthony Cooney v. Commissioner.

United States Tax Court.

Filed February 9, 1994.

Attorney(s) appearing for the Case

Edward Anthony Cooney, pro se. Carmino J. Santaniello, for the respondent.

Memorandum Opinion

LARO, Judge:

Respondent moves pursuant to Rule 121 for an order granting summary judgment in her favor on all issues in this case.1 Respondent contends that there is no issue of material fact to be resolved, and, accordingly, she is entitled to a decision in her favor as a matter of law. In response to respondent's motion, petitioner alleges in relevant part that

1. Failure to file income tax returns...

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