David Ray and Linda Lee Harris - Page 2

                            T.C. Summary Opinion 2005-25                              


                               UNITED STATES TAX COURT                                


                   DAVID RAY AND LINDA LEE HARRIS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6711-03S.             Filed March 3, 2005.                  

               David Ray and Linda Lee Harris, pro sese.                              
               Albert B. Kerkhove, for respondent.                                    


               GOLDBERG, 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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.  Unless otherwise indicated,              
          subsequent section references are to the Internal Revenue Code.             
               The petition in this case was filed in response to a Notice            
          of Determination Concerning Collection Action(s) Under Section              





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