John Mosier and Sarah Spain - Page 2
















                            T.C. Summary Opinion 2001-104                             


                               UNITED STATES TAX COURT                                


                     JOHN MOSIER AND SARAH SPAIN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9492-99S.                    Filed July 13, 2001.           


               John Mosier, pro se.                                                   
               Scott T. Welch, for respondent.                                        


               DINAN, 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           








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