Gil G. and Patroncenia C. Santilla - Page 2

                            T.C. Summary Opinion 2004-24                              


                               UNITED STATES TAX COURT                                


                  GIL G. AND PATROCENIA C. SANTILLA, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 2485-03S.           Filed March 9, 2004.                    


               Gil G. Santilla, pro se.                                               
               Donna L. Pahl, for respondent.                                         


               GOLDBERG, 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.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.  Unless otherwise indicated,              
          subsequent section references are to the Internal Revenue Code in           







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