Wm. Dennis Gray - Page 2
















                            T.C. Summary Opinion 2001-36                              


                               UNITED STATES TAX COURT                                


                           WM. DENNIS GRAY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 13062-99S.                  Filed March 21, 2001.           

               Wm. Dennis Gray, pro se.                                               
               Gerald L. Brantley, for respondent.                                    

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






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