Janet S. Shapiro - Page 2

                             T.C. Summary Opinion 2001-4                              

                               UNITED STATES TAX COURT                                

                           JANET S. SHAPIRO, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17511-99S.                Filed January 22, 2001.           

               Janet S. Shapiro, pro se.                                              
               Louise Forbes, for respondent.                                         

               PANUTHOS, Chief 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 year in issue.                               

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