Eng Guek Kang - Page 2
















                            T.C. Summary Opinion 2001-97                              


                               UNITED STATES TAX COURT                                

                            ENG GUEK KANG, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                              KOK H. NGO, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 10272-99S, 10902-99S.       Filed June 26, 2001.           

               Eng Guek Kang and Kok H. Ngo, pro sese.                                
               Julie L. Payne, for respondent.                                        

               GOLDBERG, Special Trial Judge:  These consolidated cases               
          were heard pursuant to the provisions of section 7463 of the                
          Internal Revenue Code in effect at the time each petition was               
          filed.  The decisions to be entered are not reviewable by any               
          other court, and this opinion should not be cited as authority.             
          Unless otherwise indicated, subsequent section references are to            
          the Internal Revenue Code in effect for the years in issue, and             






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