Raymond J. Davis - Page 2

                            T.C. Summary Opinion 2004-64                              


                               UNITED STATES TAX COURT                                


                           RAYMOND J. DAVIS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4536-03S.           Filed May 14, 2004.                     

               Raymond J. Davis, pro se.                                              
               Jeremy L. McPherson, for respondent.                                   


               DEAN, Special Trial Judge:  This case was heard under the              
          provisions of section 7463 of the Internal Revenue Code as in               
          effect at the time the petition was filed.  Unless otherwise                
          indicated, all other 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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