Frank J. Zavatto - Page 2

                            T.C. Summary Opinion 2001-62                              

                               UNITED STATES TAX COURT                                

                           FRANK J. ZAVATTO, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12576-99S.                  Filed April 24, 2001.           

               Frank J. Zavatto, pro se.                                              
               Caroline Tso Chen, 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.  The decision to be entered is             
          not reviewable by any other court, and this opinion should not be           
          cited as authority.                                                         

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