Michael J. Rovell - Page 2

                            T.C. Summary Opinion 2007-113                             

                               UNITED STATES TAX COURT                                

                          MICHAEL J. ROVELL, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18728-05S.            Filed July 2, 2007.                   

               Michael J. Rovell, pro se.                                             
               Julie A. Jebe, for respondent.                                         

               GOLDBERG, Special Trial 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           

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