William J. Cutts - Page 2

                             T.C. Summary Opinion 2004-8                              


                               UNITED STATES TAX COURT                                


                           WILLIAM J. CUTTS, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                     AMERICAN TANK & VESSEL, INC., Petitioner v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 10471-01S, 10472-01S. Filed January 29, 2004.              

               Irvin Grodsky, for petitioners.                                        
               Linda J. Wise, for respondent.                                         

               BEGHE, Judge:  These consolidated cases were heard pursuant            
          to section 7463 of the Internal Revenue Code in effect when the             
          petitions were filed.1  The decisions to be entered are                     



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




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