Michael O'Keefe Sowell - Page 2

                            T.C. Summary Opinion 2002-135                             

                               UNITED STATES TAX COURT                                

                        MICHAEL O’KEEFE SOWELL, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2307-01S.             Filed October 17, 2002.               

               Michael O’Keefe Sowell, pro se.                                        
               Angelique M. Neal, 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.  Petitioner filed a motion for claims for            

          1    Unless otherwise indicated, subsequent section references              
          are to the Internal Revenue Code as amended, and Rule references            
          are to the Tax Court Rules of Practice and Procedure.                       

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