Law Offices of Michael B. L. Hepps - Page 1

                                 T.C. Memo. 2005-138                                  

                               UNITED STATES TAX COURT                                

                  LAW OFFICES OF MICHAEL B. L. HEPPS, Petitioner v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20436-03.           Filed June 13, 2005.                    

               Michael Barry Loui Hepps, for petitioner.                              
               James B. Urie, for respondent.                                         

                                 MEMORANDUM OPINION                                   
               MARVEL, Judge:  This matter is before the Court on                     
          respondent’s motion for judgment on the pleadings under Rule                
          120(a) (motion).1  Because petitioner attached exhibits to its              
          response to respondent’s motion that require us to consider                 

               1All Rule references are to the Tax Court Rules of Practice            
          and Procedure, and all section references are to the Internal               
          Revenue Code in effect for the years in issue.                              

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