T.C. Summary Opinion 2001-124
UNITED STATES TAX COURT
FERNANDO D. RIVERA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3740-00S. Filed August 13, 2001.
Fernando D. Rivera, pro se.
Russell D. Pinkerton, 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. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for 1997, and 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
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