Milton Craig Werner and Barbara K. Werner - Page 2

                            T.C. Summary Opinion 2004-80                              


                               UNITED STATES TAX COURT                                


              MILTON CRAIG WERNER AND BARBARA K. WERNER, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14689-02S.             Filed June 17, 2004.                 

               Milton Craig Werner and Barbara K. Werner, pro sese.                   
               Huong T. Duong, for respondent.                                        


               DEAN, Special Trial Judge: This case was heard pursuant to             
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year at issue, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          





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