Stephen R. Barker - Page 1

                                 T.C. Memo. 2002-13                                   


                               UNITED STATES TAX COURT                                


                          STEPHEN R. BARKER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8576-00L.                 Filed January 10, 2002.           


               Stephen R. Barker, pro se.                                             
               Sheara Gelman, for respondent.                                         


                                 MEMORANDUM OPINION                                   
               ARMEN, Special Trial Judge:  This matter is before the Court           
          on respondent’s Motion for Summary Judgment, as supplemented,               
          filed pursuant to Rule 121(a).1  Respondent contends that there             
          is no dispute as to any material fact with respect to this                  


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

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