Tonia V. Cates - Page 2
















                            T.C. Summary Opinion 2003-15                              


                               UNITED STATES TAX COURT                                

                            TONIA V. CATES, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2312-01S.           Filed February 28, 2003.                

               Timothy J. Condon, Sr., for petitioner.                                
               Sean R. Gannon, for respondent.                                        


               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 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.                                           
               Respondent determined a deficiency of $8,634 in petitioner’s           
          1998 Federal income tax.  The issue is whether petitioner may               


               1  Unless otherwise indicated, subsequent section references           
          are to the Internal Revenue Code in effect for the year in issue.           




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