Gary E. and Rebecca L. Hurley - Page 2

                            T.C. Summary Opinion 2005-125                             

                               UNITED STATES TAX COURT                                

                    GARY E. AND REBECCA L. HURLEY, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20949-03S.             Filed August 16, 2005.               

               Gary E. Hurley, pro se.                                                
               John W. Strate, for respondent.                                        

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 in effect when 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.                          

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

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