Gregory C. and Phyllis Lam - Page 2

                            T.C. Summary Opinion 2003-100                             

                               UNITED STATES TAX COURT                                

                     GREGORY C. AND PHYLLIS LAM, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12153-00S.            Filed July 23, 2003.                  

               Gregory C. and Phyllis Lam, pro sese.                                  
               Margaret Rigg, for respondent.                                         

               PAJAK, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time the petition was filed.  Unless otherwise                
          indicated, section references are to the Internal Revenue Code in           
          effect for the year in issue.  The decision to be entered is not            
          reviewable by any other court, and this opinion should not be               
          cited as authority.                                                         
               Respondent determined a deficiency of $1,981 and an                    

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