Rene D. and Rosemary S. Valdes - Page 2

                            T.C. Summary Opinion 2004-19                              

                               UNITED STATES TAX COURT                                

                   RENE D. AND ROSEMARY S. VALDES, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2357-00S.            Filed February 25, 2004.               

               Rene D. Valdes, pro se.                                                
               Lorianne D. Masano, for respondent.                                    

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 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.                                           

               1  Unless otherwise indicated, subsequent section references           
          are to 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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