Jin Xiong - Page 2














                            T.C. Summary Opinion 2007-96                              


                               UNITED STATES TAX COURT                                


                              JIN XIONG, Petitioner v.                                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2795-06S.              Filed June 14, 2007.                 


               Jin Xiong, pro se.                                                     
               W. Lance Stodghill, 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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