T.C. Summary Opinion 2001-96                              
                               UNITED STATES TAX COURT                                
                      DAVID AND IRA KAYE KESSEL, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 16482-98S.                   Filed June 26, 2001.           
               David Kessel and Ira Kaye Kessel, pro sese.                            
               Rodney J. Bartlett, for respondent.                                    
               PAJAK, 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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.  Unless otherwise indicated,              
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