Borgman v. Commissioner

JOHN D. BORGMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Borgman v. Commissioner

Docket No. 17260-82.

United States Tax Court

T.C. Memo 1984-503; 1984 Tax Ct. Memo LEXIS 168; 48 T.C.M. (CCH) 1180; T.C.M. (RIA) 84503;

September 20, 1984.

Philip S. Weinstein, for the petitioner.

Albert A. Balboni, for the respondent.

SWIFT

MEMORANDUM OPINION

SWIFT, Judge: Thismatter is before the Court on petitioner's motion for summary judgment under Rule 121 of the Tax Court Rules of Practice and Procedure. All of the facts relevant to this motion have been stipulated by the parties and are…