George A. and Hilda Quintero - Page 2

                            T.C. Summary Opinion 2002-47                              

                               UNITED STATES TAX COURT                                

                    GEORGE A. AND HILDA QUINTERO, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8364-00S.            Filed May 6, 2002.                     

               Larry Fedro, for petitioners.                                          
               John T. Lortie, for respondent.                                        

               CARLUZZO, 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.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for 1997.  Rule references are to the Tax            
          Court Rules of Practice and Procedure.  The decision to be                  
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           

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