Richard D. Waters - Page 2
















                            T.C. Summary Opinion 2001-46                              


                               UNITED STATES TAX COURT                                


                          RICHARD W. WATERS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5578-99S.              Filed April 3, 2001.                 

               Bradley S. Shannon and John Howell, for petitioner.                    
               Paul K. Voelker, for respondent.                                       


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect when the petition was filed.1            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          
               Respondent determined a deficiency of $10,894 in                       


               1    Unless otherwise indicated, section references                    
          hereafter are to the Internal Revenue Code in effect for the year           
          at issue.  All Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     





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