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WOLF v. COMMISSIONER

Dkt. No. 3747-04L.

93 T.C.M. 1273 (2007)

T.C. Memo. 2007-133

Cheryl A. Wolf v. Commissioner.

United States Tax Court.

May 31, 2007.

Attorney(s) appearing for the Case

Cheryl A. Wolf, pro se.

Marc L. Caine, for respondent.

MEMORANDUM OPINION

SWIFT, Judge:

This matter is before us on respondent's Rule 53 motion to partially dismiss for lack of jurisdiction as to one matter and on respondent's Rule 121 motion for summary judgment as to all other matters.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.

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