Keith T. and Geraldine A. Bowers - Page 2

                            T.C. Summary Opinion 2003-57                              


                               UNITED STATES TAX COURT                                


                  KEITH T. AND GERALDINE A. BOWERS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 8191-00S,           Filed May 19, 2003.                    
                         10437-01S.                                                   

               Kevin G. Vanginderen, for petitioners.                                 
               Karen Nicholson Sommers, for respondent.                               


               POWELL, Special Trial Judge:  These consolidated cases were            
          heard pursuant to the provisions of section 7463 of the Internal            
          Revenue Code in effect at the time the petitions were filed.1               




          1    Unless otherwise indicated, subsequent section references              
          are to the Internal Revenue Code in effect for the years in                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     





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