Maria G. Pelayo - Page 2
















                            T.C. Summary Opinion 2003-20                              


                               UNITED STATES TAX COURT                                

                           MARIA G. PELAYO, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                             JORGE PELAYO, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 7282-01S, 7283-01S.     Filed March 14, 2003.              

               Maria G. Pelayo, pro se in docket No. 7282-01S.                        
               Jorge Pelayo, pro se in docket No. 7283-01S.                           
               Karen Nicholson Sommers, for respondent.                               

               POWELL, Special Trial Judge:  These consolidated cases1                
          were heard pursuant to the provisions of section 74632 of the               



          1   These cases were consolidated for purposes of trial,                    
          briefing, and opinion because they involve common questions of              
          fact and law arising from the alleged marital separation of                 
          petitioners.                                                                
          2   Unless otherwise indicated, subsequent section references are           
          to the Internal Revenue Code in effect for the year in issue.               





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