Peggy A. Farley - Page 1

                                 T.C. Memo. 2004-168                                  

                               UNITED STATES TAX COURT                                

                           PEGGY A. FARLEY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6897-03L.                Filed July 19, 2004.               

               Peggy A. Farley, pro se.                                               
               Brian D. Derdowski, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               PANUTHOS, Chief Special Trial Judge:  This matter is before            
          the Court on respondent’s motion for summary judgment, filed                
          pursuant to Rule 121.1  As explained in more detail below we                
          shall grant such motion.                                                    

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

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