T.C. Summary Opinion 2001-109                             
                               UNITED STATES TAX COURT                                
                            ALI MOTAGHAYER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 15237-99S.                   Filed July 25, 2001.           
               Ali Motaghayer, pro se.                                                
               Usha Ravi, for respondent.                                             
               CARLUZZO, 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.  Subsequent section              
          references are to the Internal Revenue Code in effect for 1995.             
          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.             
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