Larry E. and Barbara L. Andra - Page 2

                            T.C. Summary Opinion 2004-53                              


                               UNITED STATES TAX COURT                                


                    LARRY E. AND BARBARA L. ANDRA, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 20242-02S.           Filed May 11, 2004.                    


               Larry E. Andra, pro se.                                                
               Wesley F. McNamara, 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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