Olen W. and Gwendolyn Wilborn - Page 2

                            T.C. Summary Opinion 2003-152                             


                               UNITED STATES TAX COURT                                


                    OLEN W. AND GWENDOLYN WILBORN, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6805-02S.          Filed October 15, 2003.                  

               Olen W. and Gwendolyn Wilborn, pro sese.                               
               John F. Driscoll, for respondent.                                      


               WHERRY, Judge:  This case is before the Court on                       
          respondent’s Motion For Summary Judgment under Rule 121.1  The              
          petition was filed pursuant to the provisions of section 7463.              
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.  The instant             
          proceeding arises from a petition for judicial review filed in              

               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code of 1986, as amended, and Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       




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