Wesley T. and Ruth T. Enloe - Page 2

                            T.C. Summary Opinion 2003-81                              


                               UNITED STATES TAX COURT                                


                     WESLEY T. AND RUTH T. ENLOE, Petitioners v.                      
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     


               Docket No. 14031-01S.            Filed June 19, 2003.                  


               William J. Bergner, for petitioners.                                   
               Harriet E. Downs, for respondent.                                      


               DEAN, Special Trial Judge:  This case was heard under the              
          provisions of section 7463 of the Internal Revenue Code as in               
          effect at the time the petition was filed.  Unless otherwise                
          indicated, all subsequent section references are to the Internal            
          Revenue Code in effect for the year at issue.  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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