Tod McMullen and Robin Everson - Page 2
















                            T.C. Summary Opinion 2001-87                              


                               UNITED STATES TAX COURT                                


                   TOD McMULLEN AND ROBBIN EVERSON, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 12373-99S.                   Filed June 13, 2001.           


               Tod McMullen and Robbin Everson, pro sese.                             
               G. Michelle Ferreira, for respondent.                                  


               CARLUZZO, 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.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year in issue.  The decision to be           
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           






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