Robert Gunselman - Page 1

                                 T.C. Memo. 2003-11                                   

                               UNITED STATES TAX COURT                                

                           ROBERT GUNSELMAN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6925-02L.              Filed January 9, 2003.               

               Robert Gunselman, pro se.                                              
               James Brian Urie, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               RUWE, Judge:  This matter is before us on respondent’s                 
          motion for summary judgment under Rule 1211 and to impose a                 
          penalty under section 6673.  Respondent argues that no genuine              
          issue exists as to any material fact and that his determination             

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

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