Brian P. Keeley and Mary G. Keeley - Page 2

                            T.C. Summary Opinion 2003-53                              


                               UNITED STATES TAX COURT                                


                 BRIAN P. KEELEY AND MARY G. KEELEY, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1019-02S.             Filed May 15, 2003.                   

               Brian P. Keeley and Mary G. Keeley, pro sese.                          
               David S. Weiner, 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  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for the               
          taxable years in issue, and all Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      




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