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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