Marvin J. Lewis and Brenda J. Lewis - Page 2















          T.C. Summary Opinion 2001-142                                               


                               UNITED STATES TAX COURT                                


                 MARVIN J. LEWIS AND BRENDA J. LEWIS, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1321-00S.          Filed September 14, 2001.                


               Marvin J. Lewis and Brenda J. Lewis, pro sese.                         
               Frank N. Panza and Sherri Wilder, 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,              
          subsequent section references are to the Internal Revenue Code in           
          effect for the year in issue.                                               






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