Edward A. Birts - Page 2
















                            T.C. Summary Opinion 2001-77                              


                               UNITED STATES TAX COURT                                


                           EDWARD A. BIRTS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3914-00S.                     Filed June 4, 2001.           

               Edward A. Birts, pro se.                                               
               Marilyn S. Ames, for respondent.                                       

               ARMEN, 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.1  The decision to be             
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           


          1 Unless otherwise indicated, all subsequent section                        
          references are to the Internal Revenue Code in effect for 1997,             
          the taxable year in issue.                                                  





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