Brian Montwillo - Page 2

                            T.C. Summary Opinion 2004-123                             


                               UNITED STATES TAX COURT                                


                           BRIAN MONTWILLO, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14348-03S.           Filed September 7, 2004.               

               Brian Montwillo, pro se.                                               
               Henry E. O’Neill, for respondent.                                      

               THORNTON, 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 section references are to           
          the Internal Revenue Code in effect for the year in issue.                  





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