Marcus C. Seay - Page 1

                                 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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