James and Katie Gill - Page 2
















                            T.C. Summary Opinion 2003-24                              


                               UNITED STATES TAX COURT                                


                      JAMES GILL AND KATIE GILL, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8023-02S.             Filed March 19, 2003.                 

               James and Katie Gill, pro sese.                                        
               Michael D. Zima, for respondent.                                       


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.1  The decision to           
          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           


               1  All subsequent section references are to the Internal               
          Revenue Code in effect for 1999, the taxable year in issue.                 





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