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EISELSTEIN v. COMMISSIONER

Docket No. 7613-02L.

85 T.C.M. 794 (2003)

T.C. Memo. 2003-22

Miriam-Majadillas Eiselstein v. Commissioner.

United States Tax Court.

Filed January 22, 2003.

Attorney(s) appearing for the Case

Miriam-Majadillas Eiselstein, pro se.

Robert S. Scarbrough, for the respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before the Court on respondent's motion for summary judgment and to impose a penalty under I.R.C. section 6673.1

Rule 121(a) provides that either party may move for summary judgment upon all or any part of the legal issues in controversy. Full or partial summary judgment may be granted only if it is demonstrated that no genuine issue exists as to any material fact, and a...

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