Gary L. and Jolene K. Pendleton - Page 2

                            T.C. Summary Opinion 2001-128                             

                               UNITED STATES TAX COURT                                

                   GARY L. AND JOLENE K. PENDLETON, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14877-99S.                 Filed August 20, 2001.           

               Gary L. Pendleton and Jolene K. Pendleton, pro sese.                   
               Igor S. Drabkin, for respondent.                                       

               PAJAK, 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           
          effect for the years in issue.                                              
               Respondent determined deficiencies of $9,550 and $4,294 in             

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