Tommy Lee Randle and Joyce Faye Randle - Page 2

                            T.C. Summary Opinion 2001-115                             

                               UNITED STATES TAX COURT                                

               TOMMY LEE RANDLE AND JOYCE FAYE RANDLE, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10014-00S.           Filed July 31, 2001.                   

               Tommy Lee Randle, pro se.                                              
               Igor S. Drabkin, 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           
          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           

               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 1996,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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