William R. and Deborah L. Cramer - Page 2
















                             T.C. Summary Opinion 2003-2                              


                               UNITED STATES TAX COURT                                


                  WILLIAM R. AND DEBORAH L. CRAMER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                     FRANK E. AND GAIL L. DUNDA, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 2341-02S, 2644-02S.      Filed January 9, 2003.            

               Frank E. and Gail L. Dunda, pro sese.                                  
               William R. and Deborah L. Cramer, pro sese.                            
               Erin K. Huss, for respondent.                                          


               WOLFE, 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 that the petitions were filed.           
          The decisions to be entered are not reviewable by any other                 
          court, and this opinion should not be cited as authority.  Unless           






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