Philip M. Cavanagh - Page 2

                            T.C. Summary Opinion 2005-113                             

                               UNITED STATES TAX COURT                                

                          PHILIP M. CAVANAGH, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18772-04S.           Filed August 4, 2005.                  

               Philip M. Cavanagh, pro se.                                            
               John W. Stevens, 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 the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year in issue, and Rule references           
          are to the Tax Court Rules of Practice and Procedure.  The                  
          decision to be entered is not reviewable by any other court, and            
          this opinion should not be cited as authority.                              

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