Douglas and Carole Ritter - Page 2

                            T.C. Summary Opinion 2001-57                              

                               UNITED STATES TAX COURT                                

                      DOUGLAS AND CAROLE RITTER, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16177-99S.                  Filed April 17, 2001.           

               Douglas and Carole Ritter, pro se.                                     
               Kevin M. Murphy and Edward D. Fickess, for respondent.                 

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 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.                                           

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

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