James A. Nielsen - Page 2















                            T.C. Summary Opinion 2007-53                              


                               UNITED STATES TAX COURT                                


                           JAMES A. NIELSEN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18883-04S.            Filed April 2, 2007.                  

               James A. Nielsen, pro se.                                              
               Michael W. Bitner, for respondent.                                     


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.1  Pursuant to               
          section 7463(b), the decision to be entered is not reviewable by            



               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2000              
          and 2001, the taxable years in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           





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Last modified: November 10, 2007