Julius Lee Harrington and Mary Lou Ziter - Page 2
















                            T.C. Summary Opinion 2002-58                              


                               UNITED STATES TAX COURT                                


              JULIUS LEE HARRINGTON AND MARY LOU ZITER, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5679-00S.            Filed May 28, 2002.                    


               Julius Lee Harrington and Mary Lou Ziter, pro sese.                    
               Anne W. Durning, for respondent.                                       

               BEGHE, 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 years in issue, and all Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            





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