Robert A. White - Page 2















                           T.C. Summary Opinion 2007-199                              


                               UNITED STATES TAX COURT                                


                           ROBERT A. WHITE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8881-06S.           Filed November 26, 2007.                


               Robert A. White, pro se.                                               
               Michael A. Raiken and Scott Hovey, for respondent.                     

               PANUTHOS, Chief 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                








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