Charles J. and Hyla J. Portaluppi - Page 2
















                            T.C. Summary Opinion 2002-106                             


                               UNITED STATES TAX COURT                                


                  CHARLES J. AND HYLA J. PORTALUPPI, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5558-00S.            Filed August 12, 2002.                 


               Charles J. and Hyla J. Portaluppi, pro se.                             
               William J. Gregg, for respondent.                                      


               PANUTHOS, Chief 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.  Unless otherwise            
          indicated, subsequent section references are to the Internal                








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