Andre and Vena Nelson - Page 2

                            T.C. Summary Opinion 2004-62                              


                               UNITED STATES TAX COURT                                


                        ANDRE AND VENA NELSON, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No.  10229-03S.             Filed May 14, 2004.                 

               Andre and Vena Nelson, pro sese.                                       
               Thomas D. Yang, for respondent.                                        


               WOLFE, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect when the petition was filed.  Unless otherwise indicated,            
          all subsequent section references are to the Internal Revenue               
          Code in effect at relevant times, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure.  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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