William Richard Baker, Jr. - Page 1

                                 T.C. Memo. 2001-283                                  

                               UNITED STATES TAX COURT                                

                      WILLIAM RICHARD BAKER, JR., Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5596-99.                  Filed October 12, 2001.           

               William Richard Baker, Jr., pro se.                                    
               Edsel Ford Holman, Jr., for respondent.                                

                                 MEMORANDUM OPINION                                   

               RUWE, Judge:  This matter is before this Court on                      
          respondent’s motion for partial summary judgment, which was filed           
          pursuant to Rule 121.1  The issues for decision are whether                 

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                

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