Steven F. Darton and Paula V. Jacobs - Page 2

                            T.C. Summary Opinion 2005-188                             


                               UNITED STATES TAX COURT                                


                STEVEN F. DARTON AND PAULA V. JACOBS, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6618-04S.          Filed December 27, 2005.                 


               Steven F. Darton and Paula V. Jacobs, pro se.                          
               Marion K. Mortensen, for respondent.                                   



               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect when the petition was filed.1            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          


               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code in effect for the year at issue.           
          The Court decides this case without regard to the burden of proof           
          under sec. 7491.                                                            




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