Gary Gougler - Page 1

                                 T.C. Memo. 2002-185                                  

                               UNITED STATES TAX COURT                                

                             GARY GOUGLER, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9049-01L.               Filed July 31, 2002.                

               Gary Gougler, pro se.                                                  
               Russell K. Stewart, for respondent.                                    

                                 MEMORANDUM OPINION                                   

               COHEN, Judge:  Respondent sent to petitioner a Notice of               
          Determination Concerning Collection Action(s) Under Section 6320            
          and/or 6330 with respect to petitioner’s Federal income taxes for           
          1991 and 1992.  Petitioner contends that he did not receive a               
          refund that was due to him for 1986.  Unless otherwise indicated,           

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