DeAnna S. Dotson and Robert L. Dotson - Page 2

                            T.C. Summary Opinion 2004-164                             

                               UNITED STATES TAX COURT                                

                DEANNA S. DOTSON AND ROBERT L. DOTSON, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5321-03S.            Filed December 1, 2004.                

               DeAnna S. Dotson and Robert L. Dotson, pro sese.                       
               Peter R. Hochman, for respondent.                                      

               THORNTON, Judge:  This case was heard pursuant to section              
          7463 of the Internal Revenue Code as 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.             

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

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