Joseph A. Morcos and Joann M. Morcos - Page 2












                            T.C. Summary Opinion 2001-114                             


                               UNITED STATES TAX COURT                                


                JOSEPH A. MORCOS AND JOANN M. MORCOS, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6394-00S.            Filed July 26, 2001.                   

               Brian E. Bennett, for petitioners.                                     
               Jack T. Anagnostis, for respondent.                                    


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          
               Respondent determined deficiencies in petitioners’ 1996 and            
          1997 Federal income taxes of $10,596 and $5,790, respectively.              





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