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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