United States Tax Court
Filed: Mar. 04, 2008
T.C. Memo. 2008-50 UNITED STATES TAX COURT WILLIAM E. WARGO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9982-04. Filed March 4, 2008. Larry D. Harvey, for petitioner. Randall L. Preheim, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: This case is before the Court on respondent’s motion for summary judgment pursuant to Rule 121.1 1 Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to t..