Juan G. Ibarra and Margarita Ibarra - Page 2

                            T.C. Summary Opinion 2003-117                             


                               UNITED STATES TAX COURT                                


                    JUAN G. AND MARGARITA IBARRA, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14441-02S.             Filed August 25, 2003.               


               Juan G. and Margarita Ibarra, pro se.                                  
               Ross M. Greenberg, for respondent.                                     


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 of the Internal Revenue Code in effect             
          at the time the petition was filed.1  The decision to be entered            




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





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