T.C. Summary Opinion 2002-94                              
                               UNITED STATES TAX COURT                                
                   CRAIG A. AND ROSEANN B. MILLER, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 9973-01S.            Filed July 19, 2002.                   
               Ned Leiba, for petitioners.                                            
               Christian Speck, for respondent.                                       
               WOLFE, Special Trial 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.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  
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