Brooks Edward Omans and Tonya Renee Omans Rateau - Page 2

                            T.C. Summary Opinion 2005-110                             


                               UNITED STATES TAX COURT                                


          BROOKS EDWARD OMANS AND TONYA RENEE OMANS RATEAU, Petitioners v.            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4919-02S.             Filed August 1, 2005.                 

               Craig D. Bell and Flora Leigh T. Hezel, for petitioners.               
               Mary Ann Waters, for respondent.                                       

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 of the Internal Revenue Code             
          in effect at the time 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.                                           


          1    Unless otherwise indicated, subsequent section references              
          are to the Internal Revenue Code in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              





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