                     T.C. Memo. 2014-211



                UNITED STATES TAX COURT



            TERRY GENE AKEY, Petitioner v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent



Docket Nos. 18026-05, 18097-05,          Filed October 8, 2014.
            28057-09.



     This opinion was vacated on September 1, 2015, and replaced

by T.C. Memo. 2015-227, filed November 24, 2015, unchanged.
