Janet E. Crowell - Page 2

                            T.C. Summary Opinion 2003-134                             


                               UNITED STATES TAX COURT                                


                           JANET E. CROWELL, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

                    CLAY J. AND MONYA H. CROWELL, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 5434-02S, 5640-02S.    Filed September 26, 2003.           

               Janet E. Crowell, pro se in docket No. 5434-02S.                       
               Clay J. Crowell, pro se in docket No. 5640-02S.                        
               Susan Smith Canavello, for respondent.                                 


               COUVILLION, Special Trial Judge:  These consolidated cases             
          were heard pursuant to section 7463 of the Internal Revenue Code            
          in effect at the time the petitions were filed.1  The decisions             
          to be entered are not reviewable by any other court, and this               


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




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