Jack D. Eller - Page 2















                            T.C. Summary Opinion 2007-215                             


                               UNITED STATES TAX COURT                                


                            JACK D. ELLER, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 23041-04S.            Filed December 27, 2007.              


               I. Jay Katz, for petitioner.                                           
               Thomas M. Rath, for respondent.                                        

               CARLUZZO, Special Trial Judge:  This case was heard                    
          pursuant to the provisions of section 7463.1  Pursuant to section           
          7463(b), the decision to be entered is not reviewable by any                



               1  Unless otherwise indicated, section references are to               
          the Internal Revenue Code of 1986, as amended, in effect for                
          the relevant period.  Rule references are to the Tax Court                  
          Rules of Practice and Procedure.                                            








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