United States Court of Appeals For the Seventh Circuit Chicago, Illinois 60604 April 16, 2001 Before Hon. RICHARD A. POSNER, Circuit Judge Hon. DIANE P. WOOD, Circuit Judge Hon. ANN CLAIRE WILLIAMS, Circuit Judge

THOMAS F. GROJEAN and THERESE ] Appeal from the United GROJEAN, ] States Tax Court Petitioners-Appellants, ] ] No. 14374-98 No. 00-2252 v. ] ] COMMISSIONER OF INTERNAL REVENUE, ] Respondent-Appellee. ] ]

The opinion of this court issued on April 13, 2001, is corrected as follows: The caption should reflect that the Commissioner of Internal Revenue is the Respondent-Appellee.