Rogan C. Bird - Page 1

                                 T.C. Memo. 2007-18                                   


                               UNITED STATES TAX COURT                                


                            ROGAN C. BIRD, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9149-06L.             Filed January 29, 2007.               


               Rogan C. Bird, pro se.                                                 
               Alan Friday, for respondent.                                           


                                 MEMORANDUM OPINION                                   

               WELLS, Judge:  This matter is before the Court on                      
          respondent’s motion for summary judgment pursuant to Rule 121.1             
          The issue we must decide is whether respondent’s Appeals Office             


               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, as amended.                    





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