Alva Cotter Shell IV, Petitioner, and Jamie L. Jones, Intervenor - Page 2

                            T.C. Summary Opinion 2003-136                             


                               UNITED STATES TAX COURT                                


                       ALVA COTTER SHELL IV, Petitioner, AND                          
                            JAMIE L. JONES, Intervenor v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14736-02S.            Filed September 30, 2003.             

               Alva Cotter Shell IV, pro se.                                          
               Jamie L. Jones, pro se.                                                
               Pamela L. Mable, for respondent.                                       


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.1  The decision to           


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 1996,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      





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