Donald Marion and Bethany Diane Fenton - Page 2

                            T.C. Summary Opinion 2005-99                              



                               UNITED STATES TAX COURT                                


               DONALD MARION AND BETHANY DIANE FENTON, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1588-04S.            Filed July 21, 2005.                   


               Donald Marion and Bethany Diane Fenton, pro sese.                      
               David S. Weiner, for respondent.                                       


               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of section 7463 of the Internal Revenue Code.                
          Unless otherwise indicated, section references are to the                   
          Internal Revenue Code in effect for the year in issue.  The                 
          decision to be entered is not reviewable by any other court, and            
          this opinion should not be cited as authority.                              






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