Patrick T. McGuinness - Page 2















                            T.C. Summary Opinion 2007-81                              


                               UNITED STATES TAX COURT                                


                        PATRICK T. MCGUINNESS, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19382-05S.             Filed May 24, 2007.                  

               Patrick T. McGuinness, pro se.                                         
               Laura A. Price, for respondent.                                        


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect when the petition was filed.1  Pursuant to section                   
          7463(b), the decision to be entered is not reviewable by any                



               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code, as amended, and all            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  





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