Rodney M. Fujiyama and Vicki Ann Fujiyama - Page 2
















                            T.C. Summary Opinion 2001-105                             


                               UNITED STATES TAX COURT                                


              RODNEY M. FUJIYAMA AND VICKI ANN FUJIYAMA, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16533-99S.                   Filed July 23, 2001.           

               Rodney M. Fujiyama and Vicki Ann Fujiyama, pro se.                     
               Brian M. Harrington, for respondent.                                   


               MARVEL, Judge:  This case was heard pursuant to the                    
          provisions of section 7463 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.             




               1All 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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