Randall B. and Kay F. Ollett - Page 2

                            T.C. Summary Opinion 2004-103                             


                               UNITED STATES TAX COURT                                


                    RANDALL B. AND KAY F. OLLETT, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7096-03S.             Filed July 28, 2004.                  

               Randall B. and Kay F. Ollett, pro sese.                                
               Jason W. Anderson, 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 for the years in issue, 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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