Dianne M. and Charles H. Headen - Page 2

                            T.C. Summary Opinion 2005-33                              


                               UNITED STATES TAX COURT                                


                   DIANNE M. AND CHARLES H. HEADEN, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 20249-02S.              Filed March 28, 2005.               


               Charles H. Headen, pro se.                                             
               Lorianne Masano, for respondent.                                       

               CARLUZZO, 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.  Subsequent section              
          references are to the Internal Revenue Code in effect for 2000.             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  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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