Frank Franklin - Page 2

                            T.C. Summary Opinion 2002-13                              

                               UNITED STATES TAX COURT                                

                            FRANK FRANKLIN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15383-99S.             Filed February 14, 2002.             

               Frank Franklin, pro se.                                                
               Matthew A. Mendizabal, for respondent.                                 

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 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.  All Rule references are to the Tax Court Rules of           
          Practice and Procedure.                                                     

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