Stephan Bartsch and Eva Bartsch, a.k.a. Eva Pott Bartsch - Page 2

                             T.C. Summary Opinion 2004-3                              


                               UNITED STATES TAX COURT                                


              STEPHAN BARTSCH AND EVA BARTSCH, a.k.a. EVA POTT BARTSCH,               
                                   Petitioners v.                                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18872-02S.              Filed January 20, 2004.             

               Stephan Bartsch, pro se.                                               
               Margaret S. Rigg, 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 1999,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      




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