Marcia Tyrrell - Page 1

                                 T.C. Memo. 1995-568                                  

                               UNITED STATES TAX COURT                                

                            MARCIA TYRRELL, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10683-91.          Filed November 28, 1995.                 

               Marcia Tyrrell, pro se.                                                
               Helen F. Rogers, for respondent.                                       

                                 MEMORANDUM OPINION                                   
               HAMBLEN, Chief Judge:  This matter is before the Court on              
          respondent's motion for summary judgment pursuant to Rule 121.              
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the taxable years at issue,             
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.  Respondent's motion is based on facts deemed                
          admitted pursuant to Rule 90(c).  Petitioner failed to oppose or            
          object to respondent's motion.                                              

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