Joyce A. Siddons, Petitioner, and Richard J. Siddons, Intervenor - Page 2

                            T.C. Summary Opinion 2005-160                             

                               UNITED STATES TAX COURT                                

          JOYCE A. SIDDONS, Petitioner, AND RICHARD J. SIDDONS, Intervenor            
                   v. COMMISSIONER OF INTERNAL REVENUE, Respondent                    

               Docket No. 1188-04S.              Filed November 3, 2005.              

               Joyce A. Siddons, pro se.                                              
               Timothy S. Sinnott, for respondent.                                    

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect when 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.                          

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

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