Bruce Millard - Page 2















                            T.C. Summary Opinion 2007-86                              


                               UNITED STATES TAX COURT                                


                            BRUCE MILLARD, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4971-05S.              Filed May 29, 2007.                  


               James J. Lombardi III, for petitioner.                                 
               Nina P. Ching, 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 other court,            
          and this opinion shall not be treated as precedent for any other            
          case.                                                                       


               1 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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