Jan and Corinne Mejnartowicz - Page 2

                            T.C. Summary Opinion 2001-150                             

                               UNITED STATES TAX COURT                                

                    JAN AND CORINNE MEJNARTOWICZ, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 318-00S.                Filed September 24, 2001.           

               Jan and Corinne Mejnartowicz, pro se.                                  
               John Aletta, for respondent.                                           

               POWELL, 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.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 year in issue,           
          and Rule references are to the Tax Court Rules of Practice and              

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