Beer v. Commissioner

WILLIAM J. BEER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Beer v. Commissioner

Docket No. 19469-80.

United States Tax Court

T.C. Memo 1982-735; 1982 Tax Ct. Memo LEXIS 6; 45 T.C.M. (CCH) 401; T.C.M. (RIA) 82735;

December 27, 1982.

Robert W. Gagniuk, for the petitioner.

Kevin W. Cobb, for the respondent.

KORNER

MEMORANDUM OPINION

KORNER, Judge: This matter is before the Court on respondent's motion for summary judgment, filed pursuant to the provisions of Rule 121 of the Tax Court's Rules of Practice and Procedure.1 This motion was noticed for argument at a trial session of the Court…