Donald W. and Kathryn B. Conner - Page 2

                            T.C. Summary Opinion 2005-27                              


                               UNITED STATES TAX COURT                                


           DONALD W. AND KATHRYN B. CONNER, Petitioners v. COMMISSIONER OF            
                            INTERNAL REVENUE, Respondent                              


               Docket No. 11617-03S.           Filed March 16, 2005.                  

               Donald W. and Kathryn B. Conner, pro sese.                             
               Lauren Epstein, 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.                              
               Respondent issued petitioners a Notice of Determination                
          Concerning Collection Action(s) Under Section 6320 and/or 6330              


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended.                                      




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