Fernando D. Rivera - Page 2

                            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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