Patton v. Department of Revenue

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This matter comes before the court on a motion for summary judgment filed by Defendant (the department). Plaintiff (taxpayer) objected to the department’s motion, asserting that material issues of fact are present in the case that prevent summary judgment. Taxpayer has also advanced legal arguments in opposition to those of the department. The tax years at issue are 1998 and 1999.

II. FACTS

Either through uncontroverted assertions made by the department or taxpayer or matters stipulated before or at the hearing on this case, 1 the following material…