Denise Renee Lingwall - Page 2

                            T.C. Summary Opinion 2005-69                              

                               UNITED STATES TAX COURT                                

                        DENISE RENEE LINGWALL, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5031-04S.             Filed June 2, 2005.                   

               Denise Renee Lingwall, pro se.                                         
               John C. Schmittdiel, for respondent.                                   

               KROUPA, Judge:  This collection review proceeding was heard            
          pursuant to the provisions of section 7463 of the Internal                  
          Revenue Code 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  Subsequent section references are to the Internal Revenue           
          Code, as amended.  Rule references are to the Tax Court Rules of            
          Practice and Procedure.                                                     

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