Jack Daniel Chavez, Sr. - Page 2















                            T.C. Summary Opinion 2007-112                             


                               UNITED STATES TAX COURT                                


                       JACK DANIEL CHAVEZ, SR., Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 23941-04S, 2374-06S.    Filed July 2, 2007.                


               Paul S. Braun, for petitioner.                                         
               Kathleen Schlenzig, for respondent.                                    


               GOLDBERG, Special Trial Judge:  These cases were                       
          consolidated and heard pursuant to the provisions of section 7463           
          of the Internal Revenue Code in effect at the time the petitions            
          were filed.  Pursuant to section 7463(b), the decisions to be               
          entered are not reviewable by any other court, and this opinion             
          shall not be treated as precedent for any other case.  Unless               
          otherwise indicated, subsequent section references are to the               







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