Frederick M. Fox - Page 1

                                 T.C. Memo. 1997-440                                  

                               UNITED STATES TAX COURT                                

                           FREDERICK M. FOX, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 24822-95.              Filed September 25, 1997.            

               Frederick M. Fox, pro se.                                              
               Christine V. Olsen, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               COLVIN, Judge:  This matter is before the Court on                     
          respondent's motion for summary judgment under Rule 121.1  As               
          discussed below, we will grant respondent's motion.  We will also           

               1Rule references are to the Tax Court Rules of Practice and            
          Procedure.  Section references are to the Internal Revenue Code             
          as in effect for the years in issue.                                        

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