Garnett E. Thorpe - Page 2

                            T.C. Summary Opinion 2004-98                              

                               UNITED STATES TAX COURT                                

                          GARNETT E. THORPE, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6209-03S.            Filed July 26, 2004.                   

               Garnett E. Thorpe, pro se.                                             
               Jason W. Anderson, for respondent.                                     

               WOLFE, Special Trial Judge:  This case was heard pursuant to           
          the provisions of sections 6330(d) and 7463 of the Internal                 
          Revenue Code in effect when the petition was filed.  Unless                 
          otherwise indicated, all subsequent section references are to the           
          Internal Revenue Code in effect at relevant times.  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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