Marcelo E. Ferrada and Gloria D. Ferrada - Page 2

                            T.C. Summary Opinion 2004-93                              


                               UNITED STATES TAX COURT                                


              MARCELO E. FERRADA AND GLORIA D. FERRADA, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 3084-03S.              Filed July 19, 2004.                 


               Marcelo E. and Gloria D. Ferrada, pro sese.                            
               W. Lance Stodghill, for respondent.                                    


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code in              
          effect at the time that the petition was filed.  Unless otherwise           
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year in issue.  The decision to be           
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           






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