Ivan and Karenza A. Mirosevic - Page 2

                            T.C. Summary Opinion 2005-13                              

                               UNITED STATES TAX COURT                                

                    IVAN AND KARENZA A. MIROSEVIC, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11125-03S.           Filed February 15, 2005.               

               Ivan Mirosevic and Karenza A. Mirosevic, pro sese.                     
               William J. Gregg, for respondent.                                      

               LARO, Judge:  This case was heard pursuant to the provisions           
          of section 7463 of the Internal Revenue Code in effect when the             
          petition was filed.  The decision to be entered is not reviewable           
          by any other court, and this opinion should not be cited as                 
          authority.  Subsequent section references are to the Internal               
          Revenue Code as applicable to 2000, Rule references are to the              

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