Janet Schoene - Page 2

                            T.C. Summary Opinion 2001-14                              

                               UNITED STATES TAX COURT                                

                            JANET SCHOENE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3109-99S.                Filed February 15, 2001.           

               Hedy P. Forspan, David Herman, and Peter Mendelsohn                    
          (specially recognized), for petitioner.                                     
               Lydia A. Branche and Peter J. Labelle, 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, 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 Procedure.            

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