Nathaniel Carter - Page 2

                            T.C. Summary Opinion 2002-107                             

                               UNITED STATES TAX COURT                                

                           NATHANIEL CARTER, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No 10582-01S.            Filed August 12, 2002.                 

               Nathaniel Carter, pro se.                                              
               Michelle M. Lippert, for respondent.                                   

               DEAN, 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.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year in issue, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            

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