Christopher Michael Frazier - Page 1

                                 T.C. Memo. 2005-229                                  

                               UNITED STATES TAX COURT                                

                     CHRISTOPHER MICHAEL FRAZIER, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14372-04L.           Filed October 3, 2005.                 

               Christopher Michael Frazier, pro se.                                   
               Scott A. Hovey, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               GERBER, Chief Judge:  This case is before the Court on                 
          respondent’s motion for summary judgment.  See Rule 121.1  The              
          issue for our consideration is whether respondent abused his                

               1 All 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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