Brian David Nelson and Shauna Lee Nelson - Page 2
















                            T.C. Summary Opinion 2001-44                              


                               UNITED STATES TAX COURT                                


              BRIAN DAVID NELSON AND SHAUNA LEE NELSON, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 10322-99S.                   Filed April 2, 2001.           

               Brian David Nelson and Shauna Lee Nelson, pro sese.                    
               Robert V. Boeshaar, for respondent.                                    


               DEAN, 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.                                           
               Respondent determined a deficiency of $2,520 in petitioners’           





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