Fong v. Commissioner

MUN LI FONG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Fong v. Commissioner

Tax Ct. Dkt. No. 5217-96

United States Tax Court

T.C. Memo 1998-181; 1998 Tax Ct. Memo LEXIS 181; 75 T.C.M. (CCH) 2299;

May 14, 1998, Filed

Christian A. Speck, for respondent.

Belan Kirk Wagner, for petitioner.

SWIFT, JUDGE.

SWIFT

MEMORANDUM OPINION

SWIFT, JUDGE: This case is before the Court under Rule 121 1 on petitioner's motion for summary judgment.

As a matter of law, petitioner contends that respondent's notice of deficiency in income tax to petitioner for 1986 in the amount of $375,173 is barred by the…