Robert Lyle Verity - Page 2

                            T.C. Summary Opinion 2005-70                              


                               UNITED STATES TAX COURT                                


                          ROBERT LYLE VERITY, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2483-04S.             Filed June 6, 2005.                   


               Robert Lyle Verity, pro se.                                            
               Steven I. Josephy, for respondent.                                     


               ARMEN, 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.1  The decision to           




               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 1999              
          and 2000, the taxable years in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           




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