Mark A. Filer and Julie J. Filer - Page 2

                            T.C. Summary Opinion 2005-39                              



                               UNITED STATES TAX COURT                                


                  MARK A. FILER AND JULIE J. FILER, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 4014-04S.             Filed April 12, 2005.                 

               Mark A. Filer and Julie J. Filer, pro sese.                            
               Margaret A. Martin, 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 2001,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.  All monetary amounts are            
          rounded to the nearest dollar.                                              




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