T.C. Summary Opinion 2004-107                             
                               UNITED STATES TAX COURT                                
               WILL M. McEUEN III AND TRACY L. McEUEN, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 8668-02S.           Filed August 3, 2004.                   
               Will M. McEuen III and Tracy L. McEuen, pro sese.                      
               Timothy A. Lohrstorfer, 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 the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for the year at 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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