Joseph A. Loftus - Page 2

                            T.C. Summary Opinion 2005-164                             

                               UNITED STATES TAX COURT                                

                           JOSEPH A. LOFTUS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2137-04S.            Filed November 9, 2005.                

               Joseph A. Loftus, pro se.                                              
               Wanda M. Cohen, 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 of 1986, as amended.  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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