Charles A. Brown, Jr. and Linda L. Brown - Page 2

                            T.C. Summary Opinion 2005-85                              


                               UNITED STATES TAX COURT                                


              CHARLES A. BROWN, JR. AND LINDA L. BROWN, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18198-03S.           Filed June 16, 2005.                   

               Charles A. Brown, Jr., for petitioners.                                
               Robert F. Saal, for respondent.                                        


               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 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.                                           


               1    Unless otherwise indicated, subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          year in issue, and Rule references are to the Tax Court Rules of            
          Practice and Procedure.                                                     




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