Thomas Richard White and Donna Estes White - Page 2

                            T.C. Summary Opinion 2005-62                              


                               UNITED STATES TAX COURT                                


             THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 1815-04S.             Filed May 23, 2005.                   


               Thomas Richard White and Donna Estes White, pro sese.                  
               Martha J. Weber, 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           




               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2001,             
          the taxable year in issue.  All monetary amounts are rounded to             
          the nearest dollar.                                                         




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