T.C. Summary Opinion 2002-119
UNITED STATES TAX COURT
RICHARD M. SCHAFER & DIANE M. WOOTEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7612-02S. Filed September 16, 2002.
Richard M. Schafer and Diane M. Wooten, pro sese.
Paul R. Zamolo and Melinda G. Williams, 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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