T.C. Memo. 2006-208
UNITED STATES TAX COURT
MARCUS C. SEAY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24411-04. Filed September 27, 2006.
Marcus C. Seay, pro se.
Steven M. Webster, for respondent.
MEMORANDUM OPINION
WELLS, Judge: The instant case is before the Court on
respondent’s motion for summary judgment pursuant to Rule 121.1
After considering respondent’s motion and petitioner’s response,
1Unless otherwise indicated, all 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
year in issue.
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