David Jackson and Betty S. Jackson - Page 2

                            T.C. Summary Opinion 2005-12                              


                               UNITED STATES TAX COURT                                


                 DAVID JACKSON AND BETTY S. JACKSON, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 525-04S.              Filed February 14, 2005.              

               David and Betty S. Jackson, pro sese.                                  
               Vicken Abajian, for respondent.                                        


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of sections 6330(d) and 7463(f)(2) 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,            


               1  Unless otherwise indicated, subsequent references to                
          sections other than secs. 6320 and 6330 are to the Internal                 
          Revenue Code of 1986 in effect for 1995, 1996, 1998, 1999, 2000,            
          and 2001, the taxable years in issue, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           





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