United States Tax Court.
MEMORANDUM OPINION
CHIECHI, Judge:
This case is before the Court on respondent's motion for summary judgment (respondent's motion).
Background
The record establishes and/or the parties do not dispute the following.
Petitioner resided in Massapequa, New York, at the time he filed the petition in this case.
On June 10, 2002, respondent issued to petitioner...
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