Thomas E. Roberts - Page 2

                            T.C. Summary Opinion 2005-31                              



                               UNITED STATES TAX COURT                                


                          THOMAS E. ROBERTS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 12473-03S.           Filed March 24, 2005.                  


               Thomas E. Roberts, pro se.                                             
               Catherine S. Tyson, for respondent.                                    

               CARLUZZO, Special Trial Judge:  This section 6330(d) case              
          was heard pursuant to the provisions of section 7463.1  The                 
          decision to be entered is not reviewable by any other court, and            
          this opinion should not be cited as authority.                              



               1  Section references are to the Internal Revenue Code of              
          1986, as amended.  Rule references are to the Tax Court Rules of            
          Practice and Procedure.                                                     




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