William W. Howard - Page 1

                                 T.C. Memo. 2000-319                                  

                               UNITED STATES TAX COURT                                

                          WILLIAM W. HOWARD, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13447-99L.                Filed October 13, 2000.           

               William W. Howard, pro se.                                             
               Michael D. Zima and Kerry Bryan, for respondent.                       

                                 MEMORANDUM OPINION                                   

               ARMEN, Special Trial Judge:  This matter is before the Court           
          on respondent's Motion for Summary Judgment, filed pursuant to              
          Rule 121(a).1  As explained in detail below, we shall grant                 
          respondent’s motion.                                                        

               1  All Rule references to the Tax Court Rules of Practice              
          and Procedure, and unless otherwise indicated, all section                  
          references are to the Internal Revenue Code, as amended.                    

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