Crop Care Applicators, Inc. - Page 2

                             T.C. Summary Opinion 2001-21                             

                               UNITED STATES TAX COURT                                

                      CROP CARE APPLICATORS, INC., Petitioner v.                      
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     

               Docket No. 2996-00S.               Filed March 6, 2001.                

               William A. Duncan (an officer), for petitioner.                        
               Paul K. Webb, 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.  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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