John A. Seavey - Page 2

                             T.C. Summary Opinion 2005-8                              


                               UNITED STATES TAX COURT                                


                            JOHN A. SEAVEY, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14217-03S.            Filed January 13, 2005.               


               John A. Seavey, pro se.                                                
               Carina J. Campobasso, for respondent.                                  


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of sections 6330(d) and 7463 of the Internal                 
          Revenue Code in effect at the time that the petition was filed.             
          Unless otherwise indicated, subsequent section references are to            
          the Internal Revenue Code as in effect during the years at issue.           
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          






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