Jeffrey D. and Bonita L. Woodlee - Page 2

                            T.C. Summary Opinion 2001-110                             

                               UNITED STATES TAX COURT                                

                  JEFFREY D. AND BONITA L. WOODLEE, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10897-98S.                   Filed July 25, 2001.           

               Jeffrey D. and Bonita L. Woodlee, pro se.                              
               Ronald T. Jordan, for respondent.                                      

               CARLUZZO, 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.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for 1994.  Rule references are to the Tax            
          Court Rules of Practice and Procedure.  The decision to be                  
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           

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