Melissa L. Moloney - Page 2

                            T.C. Summary Opinion 2006-53                              

                               UNITED STATES TAX COURT                                

                          MELISSA L. MOLONEY, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 21859-04S.            Filed April 17, 2006.                 

               Melissa L. Moloney, pro se.                                            
               Bradley C. Plovan, for respondent.                                     

               CHIECHI, Judge:  This case was heard pursuant to the provi-            
          sions of section 7463 of the Internal Revenue Code in effect at             
          the time the petition was filed.1  The decision to be entered is            
          not reviewable by any other court, and this opinion should not be           
          cited as authority.                                                         

               1Hereinafter, all section references are to the Internal               
          Revenue Code in effect for 2002, the year at issue.  All Rule               
          references are to the Tax Court Rules of Practice and Procedure.            

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