Marcus V. and Polly A. Booker - Page 2

                            T.C. Summary Opinion 2005-90                              

                               UNITED STATES TAX COURT                                

                    MARCUS V. AND POLLY A. BOOKER, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 14036-03S.             Filed July 18, 2005.                 

               Marcus V. and Polly A. Booker, pro se.                                 
               Brenda M. Fitzgerald, for respondent.                                  

               COUVILLION, Special Trial Judge: This case was heard                   
          pursuant to section 7463 in effect when 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.                          

               1Unless otherwise indicated, subsequent section references             
          are to the Internal Revenue Code in effect for the years at                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     

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