William L. and Audrey K. Trace - Page 2
















                            T.C. Summary Opinion 2001-165                             


                               UNITED STATES TAX COURT                                


                   WILLIAM L. AND AUDREY K. TRACE, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11657-00S.                Filed October 16, 2001.           

               William L. Trace, pro se.                                              
               Dustin M. Starbuck, for respondent.                                    

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 7463.1  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 $3,150 in petitioners’           
          1998 Federal income tax.  The issue is whether petitioners are              
          entitled to deduct the 10-percent additional tax on early                   


          1    Subsequent section references are to the Internal Revenue              
          Code in effect for the year in issue.                                       




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