Warren McKinnley Dowdy - Page 2

                            T.C. Summary Opinion 2006-111                             


                               UNITED STATES TAX COURT                                


                        WARREN MCKINNLEY DOWDY, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 20836-04S.            Filed July 17, 2006.                  


               Warren McKinnley Dowdy, pro se.                                        
               Margaret Burow, for respondent.                                        


               CARLUZZO, Special Trial Judge:  This case for the                      
          redetermination of a deficiency 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 in           
          effect for 2001.  Rule references are to the Tax Court Rules of             
          Practice and Procedure.  The decision to be entered is not                  






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