Ronald and Nancy Sweet - Page 2
















                            T.C. Summary Opinion 2001-187                             


                               UNITED STATES TAX COURT                                

                       RONALD AND NANCY SWEET, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                           RONALD T. SWEET, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 4479-00S, 4480-00S.    Filed December 21, 2001.            

               Charles A. Borek and Robb Longman (specially recognized),              
          for petitioners.                                                            
               Chang Ted Li, for respondent.                                          

               GOLDBERG, Special Trial Judge:  These consolidated cases               
          were heard pursuant to the provisions of section 7463 of the                
          Internal Revenue Code in effect at the time each petition was               
          filed.  The decisions to be entered are not reviewable by any               
          other court, and this opinion should not be cited as authority.             
          Unless otherwise indicated, subsequent section references are to            






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