Robert Lee and Rebecca Waters - Page 2

                            T.C. Summary Opinion 2002-62                              

                               UNITED STATES TAX COURT                                

                    ROBERT LEE AND REBECCA WATERS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11643-00S.                Filed May 30, 2002.               

               Robert Lee Waters, pro se.                                             
               Alexandra E. Nicholaides, for respondent.                              

               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.1  The decision to           
          be entered in this case is not reviewable by any other court, and           
          this opinion should not be cited as authority.                              

               1 All subsequent section references are to the Internal                
          Revenue Code in effect for 1997, the taxable year in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              

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