Wally O. and Kate A. Oyelola - Page 2

                            T.C. Summary Opinion 2004-28                              


                               UNITED STATES TAX COURT                                


                    WALLY O. AND KATE A. OYELOLA, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6599-02S.             Filed March 12, 2004.                 

               Wally O. and Kate A. Oyelola, pro sese.                                
               Frank W. Louis, for respondent.                                        


               WHERRY, 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.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, section references are to                
          sections of the Internal Revenue Code in effect for the years in            
          issue, and Rule references are to the Tax Court Rules of Practice           
          and Procedure.                                                              




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