Gary W. and Darlene E. White - Page 2

                            T.C. Summary Opinion 2004-139                             


                               UNITED STATES TAX COURT                                


                    GARY W. AND DARLENE E. WHITE, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 414-03S.             Filed October 12, 2004.                

               Gary W. and Darlene E. White, pro sese.                                
               Robert S. Scarbrough, for respondent.                                  


               ARMEN, 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.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 subsequent section                  
          references are to the Internal Revenue Code in effect for 1999              
          and 2000, the taxable years in issue.  All Rule references are to           
          the Tax Court Rules of Practice and Procedure.                              




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