Raymond J. and Ilene H. Pavelko - Page 2

                            T.C. Summary Opinion 2003-94                              

                               UNITED STATES TAX COURT                                

               RAYMOND J. PAVELKO AND ILENE H. PAVELKO, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13642-01S.            Filed July 21, 2003.                  

               Raymond J. Pavelko, pro se.                                            
               Blaine C. Holiday, for respondent.                                     

               DINAN, 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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.  Unless otherwise indicated,              
          subsequent section references are to the Internal Revenue Code in           

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