Gerard R. Fitzgerald - Page 2

                            T.C. Summary Opinion 2007-55                              

                               UNITED STATES TAX COURT                                

                         GERARD R. FITZGERALD, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5544-05S.             Filed April 11, 2007.                 

               Gerard R. Fitzgerald, pro se.                                          
               Terry Serena, for respondent.                                          

               GOLDBERG, 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.  Pursuant to section 7463(b),           
          the decision to be entered is not reviewable by any other court,            
          and this opinion shall not be treated as precedent for any other            
          case.  Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect at relevant times.                      

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Last modified: November 10, 2007