Tracy L. Geaccone - Page 2














                           T.C. Summary Opinion 2007-58                               


                              UNITED STATES TAX COURT                                 


                         TRACY L. GEACCONE, Petitioner v.                             
                   COMMISSIONER OF INTERNAL REVENUE, Respondent                       


             Docket No. 3193-06S.             Filed April 17, 2007.                   

             Leonard S. Roth, for petitioner.                                         
             Susan K. Greene, for respondent.                                         


             JACOBS, Judge:  This case was heard pursuant to the                      
        provisions of section 7463 of the Internal Revenue Code in effect             
        at the time 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, subsequent section references              
        are to the Internal Revenue Code in effect for the year in issue,             








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