Sharon M. Rivera and Richard C. Rivera - Page 2

                            T.C. Summary Opinion 2004-81                              


                               UNITED STATES TAX COURT                                


               SHARON M. RIVERA AND RICHARD C. RIVERA, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4731-03S.            Filed June 23, 2004.                   

               Sharon M. and Richard C. Rivera, pro sese.                             
               Charlotte Mitchell, for respondent.                                    


               DEAN, Special Trial Judge:  This case was heard under the              
          provisions of section 7463 of the Internal Revenue Code as in               
          effect at the time the petition was filed.  Unless otherwise                
          indicated, all other section references are to the Internal                 
          Revenue Code in effect for the years at 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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