Michael Patrick and Lydia Brewer - Page 2

                            T.C. Summary Opinion 2005-92                              


                               UNITED STATES TAX COURT                                


                  MICHAEL PATRICK AND LYDIA BREWER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5381-04S.             Filed July 19, 2005.                  

               Michael Patrick Brewer and Lydia Brewer, pro sese.                     
               Ric Hulshoff, for respondent.                                          


               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of sections 6330(d) and 7463 in effect           
          at the time the petition was filed.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.  All Rule references are             
          to the Tax Court Rules of Practice and Procedure.                           




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