Stephen and Patricia Lindsey - Page 1

                                 T.C. Memo. 2002-87                                   

                               UNITED STATES TAX COURT                                

                    STEPHEN AND PATRICIA LINDSEY, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 9014-00L.             Filed April 2, 2002.                  

               Stephen and Patricia Lindsey, pro sese.                                
               Kerry H. Bryan, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               ARMEN, Special Trial Judge:  This matter is before the Court           
          on respondent’s Motion for Summary Judgment, as supplemented,               
          filed pursuant to Rule 121(a).1  Respondent contends that there             
          is no genuine issue as to any material fact and that respondent’s           

               1  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.  Unless otherwise indicated, all section            
          references are to the Internal Revenue Code, as amended.                    

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