George A. and Laurene S. Beitel - Page 2
















                            T.C. Summary Opinion 2001-101                             


                               UNITED STATES TAX COURT                                


                   GEORGE A. AND LAURENE S. BEITEL, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17769-99S.                    Filed July 5, 2001.           


               George A. and Laurene S. Beitel, pro se.                               
               Robert V. Boeshaar, for respondent.                                    

               CARLUZZO, 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 year in issue.  The decision to be           
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           







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