Bryan Douglas Emmel - Page 2














                                                                                     
          T.C. Summary Opinion 2007-205                                               


                               UNITED STATES TAX COURT                                


                         BRYAN DOUGLAS EMMEL, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 23348-06S.            Filed December 6, 2007.               


               Bryan Douglas Emmel, pro se.                                           
               David L. Zoss, for respondent.                                         


               HAINES, 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  Pursuant to section 7463(b), the             
          decision to be entered is not reviewable by any other court, and            



               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code, as amended, and Rule references are to           
          the Tax Court Rules of Practice and Procedure.  Amounts are                 
          rounded to the nearest dollar.                                              





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