Eldron U. Erbs - Page 2
















                            T.C. Summary Opinion 2001-85                              


                               UNITED STATES TAX COURT                                


                            ELDRON U. ERBS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1890-00S.                    Filed June 13, 2001.           


               Eldron U. Erbs, pro se.                                                
               James M. Klein and Mark J. Miller, for respondent.                     


               DINAN, Special Trial Judge:  The proceedings in this case              
          were conducted 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              






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