DeLinda ViAnne Rogers - Page 1

                                 T.C. Memo. 2004-245                                  

                               UNITED STATES TAX COURT                                

                        DELINDA VIANNE ROGERS, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 1803-00.              Filed October 27, 2004.               

               DeLinda ViAnne Rogers, pro se.                                         
               Aimee R. Lobo-Berg, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               WOLFE, Special Trial Judge:  This matter is before the Court           
          on respondent’s motion for summary judgment, filed pursuant to              
          Rule 121.1  The sole issue for decision is whether petitioner, an           

               1  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure, and all section references are to the               
          Internal Revenue Code in effect at relevant times.                          

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