Steven H. and Anna J. Jensen - Page 2

                            T.C. Summary Opinion 2004-75                              


                               UNITED STATES TAX COURT                                


                    STEVEN H. AND ANNA J. JENSEN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7496-03S.             Filed May 26, 2004.                   

               Steven H. and Anna J. Jensen, pro sese.                                
               Aimee R. Lobo-Berg, for respondent.                                    


               ARMEN, 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.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, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2000,             
          the taxable year in issue.  All Rule references are to the Tax              
          Court Rules of Practice and Procedure.                                      




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