Matthew D. Gilmore - Page 2

                            T.C. Summary Opinion 2004-38                              

                               UNITED STATES TAX COURT                                

                          MATTHEW D. GILMORE, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15518-03S.           Filed March 25, 2004.                  

               Matthew D. Gilmore, pro se.                                            
               Albert G. Kobylarz, Jr., for respondent.                               

               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of section 74631 of the Internal                 
          Revenue Code in effect at the time the petition was filed.  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, subsequent section references           
          are to the Internal Revenue Code in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              

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