Donald Richard Lowe - Page 2

                            T.C. Summary Opinion 2004-17                              


                               UNITED STATES TAX COURT                                


                         DONALD RICHARD LOWE, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19506-02S.            Filed February 12, 2004.              


               Donald Richard Lowe, pro se.                                           
               Dustin M. Starbuck, for respondent.                                    


               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7463 of the Internal Revenue Code in           
          effect at the time the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year 2000.  The decision to be               
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           






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