Hugh Powell Arvin - Page 2

                            T.C. Summary Opinion 2004-108                             

                               UNITED STATES TAX COURT                                

                          HUGH POWELL ARVIN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6892-03S.            Filed August 5, 2004.                  

               Hugh Powell Arvin, pro se.                                             
               D. Sean McMahon, 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 that the petition was filed.  Unless otherwise           
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the years 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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