Robert W. and Lila L. Blewett - Page 2
















                            T.C. Summary Opinion 2001-174                             


                               UNITED STATES TAX COURT                                


                    ROBERT W. AND LILA L. BLEWETT, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6277-00S.                 Filed November 8, 2001.           


               Glen G. Utzman, for petitioners.                                       
               Julie L. Payne, for respondent.                                        


               WOLFE, 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.1  The decision to be             
          entered is not reviewable by any other court, and this opinion              


               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              





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