Charles Wendell Harkey, Sr. and Barbara Anne Harkey - Page 2

                            T.C. Summary Opinion 2003-87                              


                               UNITED STATES TAX COURT                                


          CHARLES WENDELL HARKEY, SR. AND BARBARA ANNE HARKEY, Petitioners            
                                         v.                                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18187-02S.              Filed July 1, 2003.                 

               Charles Wendell Harkey, Sr., pro se.                                   
               Nancy E. Hooten, for respondent.                                       

               ARMEN, 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 that 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 references to                
          sections other than sections 6330 and 6320 are to the Internal              
          Revenue Code of 1986 as amended or in effect for 1992 and 1993.             





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