T.C. Summary Opinion 2003-11 UNITED STATES TAX COURT CALVIN L. EUBANKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9579-01S. Filed February 13, 2003. Calvin L. Eubanks, pro se. Caroline R. Krivacka, 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 in effect at the time the petition was filed. Unless otherwise indicated, subsequent references to sections other than sect..