Diep N. Hoang - Page 1

                                 T.C. Memo. 2006-47                                   

                               UNITED STATES TAX COURT                                

                            DIEP N. HOANG, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4853-04.             Filed March 20, 2006.                  

               W. Michael Thornton (specially recognized), for petitioner.1           
               Francis C. Mucciolo and Lauren B. Epstein, for respondent.             

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               VASQUEZ, Judge:  Respondent determined a $1,361 deficiency             
          in petitioner’s 2001 Federal income tax.  The issues for decision           
          are:  (1) What amount of the $2,301 in interest petitioner                  

               1  At trial, Mr. Thornton appeared on behalf of petitioner.            
          Mr. Thornton, however, did not sign the briefs filed by                     

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