Robert L. and Sara J. Helm - Page 2
















                            T.C. Summary Opinion 2002-138                             


                               UNITED STATES TAX COURT                                


                     ROBERT L. AND SARA J. HELM, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 13170-00S, 3727-02S.     Filed October 18, 2002.           

               Robert L. and Sara J. Helm, pro sese.                                  
               John A. Freeman, for respondent.                                       


               ARMEN, 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 that the petitions were                  
          filed.1  The decisions to be entered are not reviewable by any              
          other court, and this opinion should not be cited as authority.             


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for the               
          taxable years in issue, and all Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      




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