Thomas L. & C. Marlene Pias - Page 2

                            T.C. Summary Opinion 2005-138                             

                               UNITED STATES TAX COURT                                

                     THOMAS L. & C. MARLENE PIAS, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10304-04S.            Filed September 19, 2005.             

               Thomas L. and C. Marlene Pias, pro se.                                 
               James E. Schacht and Mark J. Miller, for respondent.                   

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of 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, subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          year in issue.                                                              

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