Jon R. Ecker - Page 2
















                            T.C. Summary Opinion 2002-44                              


                               UNITED STATES TAX COURT                                


                             JON R. ECKER, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5027-00S.            Filed April 29, 2002.                  

               David C. Wagner (specially recognized), for petitioner.                
               Stephen J. Neubeck, for respondent.                                    



               DEAN, 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 the year at issue.  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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