Gary F. and Helen Overstreet - Page 1

                                 T.C. Memo. 2001-13                                   

                               UNITED STATES TAX COURT                                

                    GARY F. AND HELEN OVERSTREET, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2659-00.                  Filed January 22, 2001.           

               Gary F. Overstreet and Helen Overstreet, pro sese.                     
               Robert H. Schorman, Jr., for respondent.                               

                                 MEMORANDUM OPINION                                   

               FOLEY, Judge:  By notice dated January 6, 2000, respondent             
          determined a deficiency of $47,582 relating to petitioners’ 1992            
          Federal income taxes.  All section references are to the Internal           
          Revenue Code in effect for the year in issue, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            

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