Marvin B. Hubbard - Page 2

                            T.C. Summary Opinion 2004-148                             


                               UNITED STATES TAX COURT                                


                          MARVIN B. HUBBARD, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2652-03S.             Filed October 26, 2004.               

               Marvin B. Hubbard, pro se.                                             
               Laura A. McKenna, for respondent.                                      



               COUVILLION, Special Trial Judge: This case was heard                   
          pursuant to section 7463.1  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, subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          years at issue, and all Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            





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