Bobby J. Prater - Page 1

                              T.C. Memo. 2007-241                                     

                               UNITED STATES TAX COURT                                

                           BOBBY J. PRATER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22188-06L.            Filed August 22, 2007.                

               Paul R. Tom, for petitioner.                                           
               Elizabeth Downs, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               MARVEL, Judge:  This matter is before the Court on                     
          respondent’s motion for summary judgment, filed under Rule 121.1            

               1All 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 years at issue.                              

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Last modified: November 10, 2007