Rodolfo Garcia, Jr. and Penny A. Garcia - Page 2

                             T.C. Summary Opinion 2005-2                              


                               UNITED STATES TAX COURT                                


               RODOLFO GARCIA, JR. AND PENNY A. GARCIA, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16010-03S.           Filed January 3, 2005.                 

               Rodolfo Garcia, Jr. and Penny A. Garcia, pro sese.                     
               Thomas L. Fenner, for respondent.                                      


               KROUPA, Judge:  This case was heard pursuant to the                    
          provisions of section 74631 of the Internal Revenue Code in                 
          effect at the time of trial.  The decision to be entered is not             
          reviewable by any other court, and this opinion should not be               
          cited as authority.                                                         


               1All section references are to the Internal Revenue Code in            
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  




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