James L. Geary and Carol O. Geary - Page 2

                            T.C. Summary Opinion 2005-16                              


                               UNITED STATES TAX COURT                                


                  JAMES L. GEARY AND CAROL O. GEARY, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11327-04S.           Filed February 16, 2005.               

               James L. Geary and Carol O. Geary, pro sese.                           
               Dennis R. Onnen and Robin Ferguson, 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           
          be entered is not reviewable by any other court, and this opinion           
          should not be cited as authority.                                           



               1  All subsequent section references are to the Internal               
          Revenue Code, as amended.  All Rule references are to the Tax               
          Court Rules of Practice and Procedure.                                      




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