Richard D. Smart - Page 2

                            T.C. Summary Opinion 2006-177                             


                               UNITED STATES TAX COURT                                


                           RICHARD D. SMART, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 12217-05S.            Filed October 25, 2006.               

               Richard D. Smart, pro se.                                              
               Joseph T. Ferrick, for respondent.                                     


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect when 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.                                                      


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2002,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      




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