Jean I. Tedford - Page 2

                            T.C. Summary Opinion 2004-132                             


                               UNITED STATES TAX COURT                                


                           JEAN I. TEDFORD, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4754-03S.          Filed September 22, 2004.                


               Ernesto Pineda, for petitioner.                                        
               Sheila R. Pattison, for respondent.                                    


               HAINES, Judge:  This case was heard pursuant to section 7463           
          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, all section references are to           
          the Internal Revenue Code for the relevant year, and all Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          Amounts are rounded to the nearest dollar.                                  




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