Ronald L. DeVault - Page 2

                            T.C. Summary Opinion 2004-122                             

                               UNITED STATES TAX COURT                                

                          RONALD L. DEVAULT, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3946-03S.             Filed September 7, 2004.              

               Ronald L. DeVault, pro se.                                             
               Robert V. Boeshaar, for respondent.                                    

               ARMEN, 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.1  The decision to be             
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           

               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2000,             
          the taxable year in issue.  All Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      

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