Robert E. Austin, Jr. - Page 2

                            T.C. Summary Opinion 2007-23                              


                               UNITED STATES TAX COURT                                


                        ROBERT E. AUSTIN, JR., Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 12118-04S.            Filed February 20, 2007.              

               Robert E. Austin, Jr., pro se.                                         
               Michael D. Zima, for respondent.                                       


               COUVILLION, Special Trial Judge: This case was heard                   
          pursuant to section 7463 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.                          
               Some of the facts were stipulated.  Those facts, with the              
          annexed exhibits, are so found and are incorporated herein by               


               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code as amended.                                




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