Peter J. Tkac - Page 2
















                            T.C. Summary Opinion 2001-175                             


                               UNITED STATES TAX COURT                                


                            PETER J. TKAC, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3556-00S.                Filed November 14, 2001.           


               Peter J. Tkac, pro se.                                                 
               Roger W. Bracken, for respondent.                                      


               GERBER, 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.1  The decision to be entered            
          may not be reviewed by any other court, and this opinion should             
          not be cited as authority.                                                  


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




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