William Lenehan III and Barbara Lenehan - Page 2
















                            T.C. Summary Opinion 2002-124                             


                               UNITED STATES TAX COURT                                


               WILLIAM LENEHAN III AND BARBARA LENEHAN, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2653-01S.             Filed October 2, 2002.                

               Andrew Shabshelowitz, for petitioners.                                 
               Christine Colley, for respondent.                                      


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.1  The decision to           
          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           


               1Unless otherwise indicated, all subsequent section and                
          subtitle references are to the Internal Revenue Code in effect              
          for 1997, the taxable year in issue, and all Rule references are            
          to the Tax Court Rules of Practice and Procedure.                           




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