T.C. Summary Opinion 2006-167                             
                               UNITED STATES TAX COURT                                
                            DANIEL M. GRAY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 23314-04S.            Filed October 18, 2006.               
               Daniel M. Gray, pro se.                                                
               Michael E. Melone, for respondent.                                     
               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463.  Unless otherwise indicated, all            
          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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