Alan R. Wylie - Page 1

                                 T.C. Memo. 2001-65                                   

                               UNITED STATES TAX COURT                                

                            ALAN R. WYLIE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6949-00L.                   Filed March 20, 2001.           

               Thomas W. Roberts, for petitioner.                                     
               Karen Nicholson Sommers, for respondent.                               

                                 MEMORANDUM OPINION                                   

               LARO, Judge:  This case is based on a petition filed under             
          section 6330(d).1  Respondent moved for summary judgment under              
          Rule 121(a) on November 6, 2000.  The Court, by order dated                 
          November 8, 2000, required petitioner to respond to respondent’s            

               1Unless otherwise indicated, section references are to the             
          Internal Revenue Code applicable to the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            

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