Gunter R. and Jay R. Wall - Page 2

                            T.C. Summary Opinion 2003-165                             


                               UNITED STATES TAX COURT                                


                      GUNTER R. AND JAY R. WALL, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 13998-02S.          Filed December 11, 2003.                

               Gunter R. Wall, pro se.                                                
               Paul J. Krazeise, Jr., for respondent.                                 


               GOLDBERG, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7463.1  The decision to be entered             
          is not reviewable by any other court, and this opinion should not           
          be cited as authority.  This case arises from a petition for                
          judicial review filed in response to a Notice of Determination              
          Concerning Collection Action(s) Under Section 6320 and/or 6330.             


          1Unless otherwise indicated, section references are to the                  
          Internal Revenue Code, as amended.                                          




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