James W. Davis and Teri A. Davis - Page 2

                            T.C. Summary Opinion 2005-61                              


                               UNITED STATES TAX COURT                                


                  JAMES W. DAVIS AND TERI A. DAVIS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8590-04S.             Filed May 19, 2005.                   

               James W. Davis, pro se.                                                
               Michael J. Proto, 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 that 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 2001,             
          the taxable year in issue.  All monetary amounts are rounded to             
          the nearest dollar.                                                         




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