Clarence Michael Cherveny - Page 2
















                            T.C. Summary Opinion 2001-95                              


                               UNITED STATES TAX COURT                                


                      CLARENCE MICHAEL CHERVENY, Petitioner v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7621-99S.                    Filed June 26, 2001.           

               Clarence Michael Cherveny, pro se.                                     
               Michael O'Donnell, for respondent.                                     

               PAJAK, Special Trial Judge: This case was heard pursuant to            
          section 7463.  Unless otherwise indicated, all 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.  The decision to be entered is not reviewable by             
          any other court, and this opinion should not be cited as                    
          authority.                                                                  
               This case is before the Court pursuant to petitioner's oral            






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