Devery W. Hennard - Page 1

                                 T.C. Memo. 2005-275                                  

                               UNITED STATES TAX COURT                                

                          DEVERY W. HENNARD, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17170-04.               Filed November 28, 2005.            

               Devery W. Hennard, pro se.                                             
               Adam L. Flick, for respondent.                                         

                                 MEMORANDUM OPINION                                   

               WELLS, Judge:  This matter is before the Court on                      
          respondent’s motion for summary judgment pursuant to Rule 121.              
          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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