Charles R. Cutler - Page 1

                                 T.C. Memo. 2007-348                                  

                              UNITED STATES TAX COURT                                 

                          CHARLES R. CUTLER, Petitioner v.                            
                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 7590-02.           Filed November 26, 2007.                 

               Charles R. Cutler, pro se.                                             
               Scott T. Welch, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               HAINES, Judge:  This case is before the Court on                       
          respondent’s motion for summary judgment filed pursuant to Rule             
          121.1  Respondent argues that the factual allegations deemed                

               1All section references are to the Internal Revenue Code, as           
          amended.  Rule references are to the Tax Court Rules of Practice            
          and Procedure.  Amounts are rounded to the nearest dollar.                  

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Last modified: March 27, 2008