Frank de Bane and Kathleen Naber-de Bane - Page 2

                             T.C. Summary Opinion 2002-5                              

                               UNITED STATES TAX COURT                                

              FRANK DE BAN� AND KATHLEEN NABER-DE BAN�, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5200-00S.            Filed January 22, 2002.                

               Frank de Ban�, pro se.                                                 
               Jeremy L. McPherson, for respondent.                                   

               DINAN, 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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