Alfredo A. and Jane R. Galagar - Page 2

                            T.C. Summary Opinion 2004-39                              

                               UNITED STATES TAX COURT                                

                   ALFREDO A. AND JANE R. GALAGAR, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5906-02S.            Filed March 25, 2004.                  

               Alfredo A. Galagar, pro se.                                            
               Ric D. Hulshoff, for respondent.                                       

               PAJAK, 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.  Unless otherwise                
          indicated, section references are to the Internal Revenue Code in           
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure.  The decision to be              
          entered is not reviewable by any other court, and this opinion              
          should not be cited as authority.                                           

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