Richard B. May and Jane M. May - Page 2

                            T.C. Summary Opinion 2005-146                             


                               UNITED STATES TAX COURT                                


                   RICHARD B. MAY AND JANE M. MAY, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 5032-04S.              Filed October 11, 2005.              

               Richard B. May and Jane M. May, pro sese.                              
               Jennifer S. McGinty, for respondent.                                   


               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 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, and this opinion           
          should not be cited as authority.                                           


               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 1996              
          and 1997, the taxable years in issue.  All monetary amounts are             
          rounded to the nearest dollar.                                              




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