John and Michele McGovern - Page 2

                            T.C. Summary Opinion 2003-137                             

                               UNITED STATES TAX COURT                                

                      JOHN AND MICHELE MCGOVERN, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 19183-02S.           Filed September 30, 2003.              

               John McGovern and Michele McGovern, pro se.                            
               James Brian Urie, for respondent.                                      

               PANUTHOS, Chief 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.                              

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