Shirley Westerhuis - Page 2

                                                                                     









                            T.C. Summary Opinion 2003-116                             


                               UNITED STATES TAX COURT                                


                         SHIRLEY WESTERHUIS, Petitioner, AND                          
                         WILLIAM R. TIPPING, Intervenor v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 9568-02S.            Filed August 20, 2003.                 

               Shirley Westerhuis, pro se.                                            
               William R. Tipping, pro se.                                            
               J. Michael Melvin, for respondent.                                     


               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 of the Internal Revenue Code             
          in effect at the time the petition was filed.  The decision to be           


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





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