Mark E. Picou - Page 2

                            T.C. Summary Opinion 2006-82                              


                               UNITED STATES TAX COURT                                


                            MARK E. PICOU, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 10879-05S, 24363-05S.    Filed May 22, 2006.               

               Mark E. Picou, pro se.                                                 
               Michael W. Bitner, for respondent.                                     


               ARMEN, Special Trial Judge:  These consolidated cases were             
          heard pursuant to the provisions of section 7463 of the Internal            
          Revenue Code in effect when the petitions were filed.1  The                 
          decisions to be entered are not reviewable by any other court,              
          and this opinion should not be cited as authority.                          


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2002              
          and 2003, the taxable years in issue.  All monetary amounts are             
          rounded.                                                                    




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