MEMORANDUM OPINION
HAMBLEN, Chief Judge:
This matter is before the Court on respondent's motion for summary judgment pursuant to Rule 121. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent's motion is based on facts deemed admitted pursuant to Rule 90(c). Petitioner failed to oppose or object...
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