Ricky C. Hutchinson and Tammy L. McNichol - Page 2

                            T.C. Summary Opinion 2005-58                              


                               UNITED STATES TAX COURT                                


              RICKY C. HUTCHINSON AND TAMMY L. McNICHOL, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11690-02S.             Filed May 18, 2005.                  

               Stephen T. Walzak, for petitioners.                                    
               Alexandra E. Nicholaides, for respondent.                              


               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 of the Internal Revenue Code in effect             
          at the time 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, section references are to the              
          Internal Revenue Code in effect for the year at issue.                      





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