Michael Robert Cottrell - Page 2

                            T.C. Summary Opinion 2003-162                             


                               UNITED STATES TAX COURT                                


                       MICHAEL ROBERT COTTRELL, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 127-03S.             Filed November 18, 2003.               


               Michael Robert Cottrell, pro se.                                       
               Douglas S. Polsky, for respondent.                                     


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 of the Internal Revenue Code in effect             
          at the time the petition was filed.1  The decision to be entered            



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





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