Hilario M. and Cathy C. Aguirre - Page 2


                            T.C. Summary Opinion 2003-33                              

                               UNITED STATES TAX COURT                                

              HILARIO M. AGUIRRE AND CATHY C. AGUIRRE, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7837-01S.              Filed April 2, 2003.                 

               Hilario M. Aguirre and Cathy C. Aguirre, pro sese.                     
               David B. Mora, 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.  Subsequent section              
          references are to the Internal Revenue Code in effect for 1998.             
          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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