Wayne Robert and Patricia A. Rogers - Page 2
















                           T.C. Summary Opinion 2001-188                              


                               UNITED STATES TAX COURT                                


                WAYNE ROBERT AND PATRICIA A. ROGERS, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


              Docket No. 1068-01S.        Filed December 21, 2001.                    

              Wayne Robert and Patricia A. Rogers, pro sese.                          
              Louise R. Forbes, 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 1997              
          and 1998, the taxable years in issue.                                       





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