Daniel Hubbard - Page 2

                            T.C. Summary Opinion 2006-193                             


                               UNITED STATES TAX COURT                                


                            DANIEL HUBBARD, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8207-05S.          Filed December 21, 2006.                 


               Daniel Hubbard, pro se.                                                
               Steven Josephy, for respondent.                                        


               GOLDBERG, 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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           
               This matter is before the Court on respondent’s Motion for             
          Summary Judgment filed pursuant to Rule 121, Tax Court Rules of             






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