Robert Irwin Solomon - Page 2

                            T.C. Summary Opinion 2001-53                              

                               UNITED STATES TAX COURT                                

                         ROBERT IRWIN SOLOMON, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7700-99S.                   Filed April 11, 2001.           

               Robert Irwin Solomon, pro se.                                          
               Dustin M. Starbuck, for respondent.                                    

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 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.                                           

          1  Unless otherwise indicated, subsequent section references are            
          to the Internal Revenue Code in effect for the year in issue.               

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