Calvin L. Eubanks - Page 2
















                            T.C. Summary Opinion 2003-11                              


                               UNITED STATES TAX COURT                                


                          CALVIN L. EUBANKS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9579-01S.              Filed February 13, 2003.             


               Calvin L. Eubanks, pro se.                                             
               Caroline R. Krivacka, for respondent.                                  


               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of sections 6330(d) and 7463 of the Internal              
          Revenue Code in effect at the time the petition was filed.                  
          Unless otherwise indicated, subsequent references to sections               
          other than sections 6320 and/or 6330 are to the Internal Revenue            
          Code of 1986, as amended and in effect for 1992.  Rule references           
          are to the Tax Court Rules of Practice and Procedure.  The                  






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