Earl R. and Mary A. Palmer - Page 2
















                             T.C. Summary Opinion 2003-5                              


                               UNITED STATES TAX COURT                                


                     EARL R. AND MARY A. PALMER, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3233-01S.              Filed January 14, 2003.              

               Earl R. and Mary A. Palmer, pro se.                                    
               Brook D. Remick, for respondent.                                       


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 74631 in effect at the time the petition was            
          filed.  The decision to be entered in this case is not reviewable           
          by any other court, and this opinion should not be cited as                 
          authority.                                                                  




               1    Unless otherwise indicated, section references are to             
          the Internal Revenue Code in effect for the year at issue.                  





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