Michael Ferguson - Page 2

                            T.C. Summary Opinion 2007-30                              


                               UNITED STATES TAX COURT                                


                           MICHAEL FERGUSON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 21315-05S.             Filed February 28, 2007.             

               Michael Ferguson, pro se.                                              
               Julie A. Jebe, 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            



               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2003,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      





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