T.C. Summary Opinion 2004-151
UNITED STATES TAX COURT
DANIEL S. AND CHRISTI L. SMITH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8617-04S. Filed November 3, 2004.
Daniel S. and Christi L. Smith, pro sese.
Aimee R. Lobo-Berg, for respondent.
CARLUZZO, 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. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for 2002. Rule references are to the Tax
Court Rules of Practice and Procedure. The decision to be
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