Ronald W. Ramey and Joni J. Ramey - Page 2




                                                                                     










                            T.C. Summary Opinion 2001-156                             



                               UNITED STATES TAX COURT                                


                  RONALD W. RAMEY AND JONI J. RAMEY, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1776-00S.          Filed September 26, 2001.                


               Douglas S. Chiapuzio, for petitioners.                                 
               Robert V. Boeshaar, for respondent.                                    


               GERBER, 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.1  The decision to be entered            
          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      


               1 Unless otherwise indicated, all subsequent sections refer            
          to the Internal Revenue Code in effect for the year in issue.               




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