Bryan D. Watson, Jr., and Abigail S. Pfisterer - Page 2

                            T.C. Summary Opinion 2005-123                             


                               UNITED STATES TAX COURT                                


          BRYAN D. WATSON, JR., AND ABIGAIL S. PFISTERER, Petitioners v.              
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                


               Docket No. 19299-04S.            Filed August 11, 2005.                


               Bryan B. Watson, Jr., and Abigail S. Pfisterer, pro sese.              
               Stephen P. Baker, for respondent.                                      


               LARO, 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.  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               
          applicable version of the Internal Revenue Code.                            







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