Robert C. and Carol S. Jacobsen - Page 2

                            T.C. Summary Opinion 2002-87                              

                               UNITED STATES TAX COURT                                

              ROBERT C. JACOBSEN AND CAROL S. JACOBSEN, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13414-00S.            Filed July 11, 2002.                  

               Robert C. Jacobsen and Carol S. Jacobsen, pro se.                      
               Robert B. Taylor, for respondent.                                      

               COHEN, 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, all section             
          references are to the Internal Revenue Code in effect for the               

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