Gerald Barlow - Page 2

                            T.C. Summary Opinion 2005-50                              

                               UNITED STATES TAX COURT                                

                            GERALD BARLOW, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5956-04S.            Filed April 19, 2005.                  

               Gerald Barlow, pro se.                                                 
               Lauren B. Epstein, for respondent.                                     

               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of section 7463 of the Internal                  
          Revenue Code in effect when 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.  Unless otherwise                 
          indicated, all subsequent section references are to the Internal            
          Revenue Code in effect at relevant times.                                   

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