Choong H. Koh v. Commissioner

T.C. Memo. 2020-77

UNITED STATES TAX COURT CHOONG H. KOH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9033-19. Filed June 4, 2020. Frank Agostino, for petitioner. Thomas A. Deamus, for respondent. MEMORANDUM OPINION GREAVES, Judge: This matter is before the Court on petitioner’s motion for judgment on the pleadings under Rule 120(a)1 (motion). Petitioner seeks 1 Unless otherwise noted, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect at all relevant times. -2- [*2] judgment on…