Theldon and Mary Parrett - Page 2

                            T.C. Summary Opinion 2002-72                              

                               UNITED STATES TAX COURT                                

                      THELDON AND MARY PARRETT, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11502-01S.              Filed June 12, 2002.                

               Mary Parrett, pro se.                                                  
               Douglas S. Polsky, for respondent.                                     

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 of the Internal Revenue Code in effect             
          at the time 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.                                                      

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

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