Don Evan and Vicky Kay Whitinger - Page 2

                            T.C. Summary Opinion 2005-163                             


                               UNITED STATES TAX COURT                                


                  DON EVAN AND VICKY KAY WHITINGER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8529-04S.            Filed November 8, 2005.                


               Don Evan and Vicky Kay Whitinger, pro sese.                            
               Catherine Campbell, for respondent.                                    


               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of sections 6330(d) and 7463 of the Internal              
          Revenue Code of 1986, as amended, in effect at the time the                 
          petition was filed.1  The decision to be entered is not                     




               1  Unless otherwise indicated, subsequent section references           
          are to the Internal Revenue Code of 1986, as amended, in effect             
          for the relevant period.                                                    




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