Donnell Floyd - Page 2

                            T.C. Summary Opinion 2002-92                              

                               UNITED STATES TAX COURT                                

                            DONNELL FLOYD, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2619-01S.             Filed July 17, 2002.                  

               Donnell Floyd, pro se.                                                 
               David R. Jojola, for respondent.                                       

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 of the Internal Revenue Code in effect             
          at the time the petition was filed.1  The decision to be entered            
          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      

               1    Unless otherwise indicated, subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          year at issue.                                                              

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