Joseph C. Minneman - Page 2

                           T.C. Summary Opinion 2001-122                              

                               UNITED STATES TAX COURT                                

                         JOSEPH C. MINNEMAN, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

              Docket No. 13558-99S.                  Filed August 7, 2001.            

              Joseph C. Minneman, pro se.                                             
              Michael F. O’Donnell, for respondent.                                   

              ARMEN, Special Trial Judge:  This case was heard pursuant to            
         the provisions of section 7463 of the Internal Revenue Code in               
         effect at the time that the petition was filed.1  The decision to            

               1 Unless otherwise indicated, all subsequent section                   
          references are to the Internal Revenue Code in effect for 1989,             
          the only taxable year remaining in issue, and all Rule references           
          are to the Tax Court Rules of Practice and Procedure.  All                  
          amounts are rounded to the nearest dollar.                                  

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