Charles W. and Nancy T. Smith - Page 2

                            T.C. Summary Opinion 2003-167                             


                               UNITED STATES TAX COURT                                


                    CHARLES W. AND NANCY T. SMITH, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15754-02S.            Filed December 17, 2003.              

               Charles W. and Nancy T. Smith, pro se.                                 
               Susan Smith Canavello, for respondent.                                 


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect at the time 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.             
               Respondent determined a deficiency of $7,146 in petitioners'           
          Federal income tax for 2000.                                                


               1    Unless otherwise indicated, subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          year at issue.                                                              




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