T.C. Summary Opinion 2001-161
UNITED STATES TAX COURT
ROBERT WALTER ALLISON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13733-99S. Filed October 11, 2001.
Robert Walter Allison, pro se.
John W. Stevens and Robert D. Heitmeyer, for respondent.
GOLDBERG, Special Trial Judge: This case was heard pursuant
to the provisions of section 7463 of the Internal Revenue Code in
effect at the time the petition was filed. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority. Unless otherwise indicated,
subsequent section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
In a notice of deficiency, respondent determined that
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