James P. Ellis - Page 2

                            T.C. Summary Opinion 2004-170                             


                               UNITED STATES TAX COURT                                


                            JAMES P. ELLIS, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11098-03S.            Filed December 20, 2004.              


               James P. Ellis, pro se.                                                
               Cynthia J. Olson, 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 in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            







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