Rosiland J. Smith - Page 2
















                            T.C. Summary Opinion 2001-130                             


                               UNITED STATES TAX COURT                                


                          ROSILAND J. SMITH, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3576-00S.                  Filed August 22, 2001.           

               James Wesly Smith, for petitioner.                                     
               Lorraine Y. Wu, for respondent.                                        


               PAJAK, 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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