Rolly J. and Joann M. Sorrentino - Page 2
















                            T.C. Summary Opinion 2001-123                             


                               UNITED STATES TAX COURT                                


                  ROLLY J. AND JOANN M. SORRENTINO, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3288-00S.                   Filed August 8, 2001.           

               Rolly J. Sorrentino, pro se.                                           
               Randall L. Preheim, for respondent.                                    


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect when 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.                          
               Respondent determined a deficiency of $3,626 in petitioners'           
          1995 Federal income tax.                                                    


               1    Unless otherwise indicated, section references                    
          hereafter are to the Internal Revenue Code in effect for the year           
          at issue.                                                                   




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