John Michael Kernan - Page 2

                            T.C. Summary Opinion 2002-148                             

                               UNITED STATES TAX COURT                                

                         JOHN MICHAEL KERNAN, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5655-01S.              Filed November 20, 2002.             

               John Michael Kernan, pro se.                                           
               Alvin A. Ohm, 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 $14,364 in                       
          petitioner's Federal income tax for 1996.                                   

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

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