T.C. Summary Opinion 2004-173
UNITED STATES TAX COURT
JAMES EDWARD AND BRENDA DIANNE STARKOVICH, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3979-04S. Filed December 21, 2004.
James Edward and Brenda Dianne Starkovich, pro sese.
Abbey B. Garber, for respondent.
DEAN, 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. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure. The decision
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