Jeffrey M. Young - Page 1

                                  T.C. Memo. 2003-6                                   

                               UNITED STATES TAX COURT                                

                           JEFFREY M. YOUNG, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1193-02L.            Filed January 8, 2003.                 

               Jeffrey M. Young, pro se.                                              
               Jeffrey C. Venzie, 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 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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