Richard A. Mullen - Page 2

                            T.C. Summary Opinion 2006-91                              

                               UNITED STATES TAX COURT                                

                          RICHARD A. MULLEN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5187-05S.              Filed May 30, 2006.                  

               Richard A. Mullen, pro se.                                             
               Louise R. Forbes, 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 2003.  The decision to be entered is not reviewable by           

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