T.C. Summary Opinion 2006-176
UNITED STATES TAX COURT
PATRICK M. SHANNON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9574-05S. Filed October 25, 2006.
Patrick M. Shannon, pro se.
Lisa K. Hunter, for respondent.
CHIECHI, Judge: This case is before the Court on respon-
dent’s motion for summary judgment (respondent’s motion)1 and was
heard pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect at the time that the petition was filed.2
1Although the Court ordered petitioner to file a response to
respondent’s motion, petitioner failed to do so.
2All section references are to the Internal Revenue Code in
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