Ronald A. Horton - Page 2

                            T.C. Summary Opinion 2005-136                             

                               UNITED STATES TAX COURT                                

                           RONALD A. HORTON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17058-04S.            Filed September 15, 2005.             

               Robert L. Stephens, Jr., for petitioner.                               
               Robert V. Boeshaar, for respondent.                                    

               NIMS, Judge:   This case was heard pursuant to section 7463            
          of the Internal Revenue Code in effect at the time the petition             
          was filed.  The decision to be entered is not reviewable by any             
          other court, and this opinion may not be cited as authority.                
          Unless otherwise indicated, all other section references are to             

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