Noel Colstock - Page 2

                            T.C. Summary Opinion 2005-54                              

                               UNITED STATES TAX COURT                                

                            NOEL COLSTOCK, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22258-03S.           Filed April 25, 2005.                  

               Noel Colstock, pro se.                                                 
               Miriam C. Dillard, 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 that the petition was filed.  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.            
          The decision to be entered is not reviewable by any other court,            

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