Johnny and M. Suzan Black - Page 2

                            T.C. Summary Opinion 2005-46                              

                               UNITED STATES TAX COURT                                

              JOHNNY AND M. SUZAN BLACK, Petitioners v. COMMISSIONER OF               
                            INTERNAL REVENUE, Respondent                              

               Docket No. 16246-04S.             Filed April 18, 2005.                

               Johnny Black and M. Suzan Black, pro sese.                             
               Erin K. Huss, for respondent.                                          

               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of sections 6330(d) and 7463.1  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, all section references are to           
          the Internal Revenue Code, as amended.                                      

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