William C. Stearman III - Page 1

                                 T.C. Memo. 2005-39                                   

                               UNITED STATES TAX COURT                                

                       WILLIAM C. STEARMAN III, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 20928-03, 15561-04.    Filed March 3, 2005.                

               William C. Stearman III, pro se.                                       
               Donna B. Read, for respondent.                                         

                                 MEMORANDUM OPINION                                   

               VASQUEZ, Judge:  These cases are before the Court on                   
          respondent’s motions to dismiss for failure to state a claim upon           
          which relief could be granted and to impose a penalty under                 
          section 6673(a).1                                                           

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              

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