Robert B. and Betty D. Harris - Page 2
















                            T.C. Summary Opinion 2001-42                              


                               UNITED STATES TAX COURT                                


                    ROBERT B. AND BETTY D. HARRIS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19681-98S.                  Filed March 27, 2001.           

               Robert D. Hyde, for petitioners.                                       
               Martha J. Weber, for respondent.                                       


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to 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.             




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





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