Robert Walter Allison - Page 2

                            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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