Edward C. Rosa - Page 2

                            T.C. Summary Opinion 2005-53                              

                               UNITED STATES TAX COURT                                

                            EDWARD C. ROSA, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8299-03S.            Filed April 25, 2005.                  

               Edward C. Rosa, 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 the petition was filed.  Unless otherwise                
          indicated, all 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,            
          and this opinion should not be cited as authority.                          

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