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CAPPUCCI v. COMMISSIONER

Docket No. 1967-00.

82 T.C.M. 1011 (2001)

T.C. Memo. 2001-322

Francesca Cappucci v. Commissioner.

United States Tax Court.

Filed December 28, 2001.

Attorney(s) appearing for the Case

Francesca Cappucci, pro se. Angelique M. Neal, for the respondent.

MEMORANDUM OPINION

GERBER, Judge:

Respondent moved for summary judgment on the question of whether petitioner is entitled to administrative costs under section 74301 in excess of those allowed by respondent. There is no disagreement about any material facts, and the controverted issue involves a legal question that is ripe for summary judgment. Rule 121(b); Fla. Peach Corp. v. Commissioner [Dec. 44,689],

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