Michael Davon Westbrook - Page 2

                             T.C. Summary Opinion 2006-3                              


                               UNITED STATES TAX COURT                                


                       MICHAEL DAVON WESTBROOK, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8170-04S.            Filed January 3, 2006.                 

               Michael Davon Westbrook, pro se.                                       
               Frank J. Jackson, for respondent.                                      


               CARLUZZO, 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.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for 2000.  Rule references are to the Tax            
          Court Rules of Practice and Procedure.  The decision to be                  








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