William H. Mansel, Jr. and Angela W. Mansel - Page 2

                            T.C. Summary Opinion 2005-157                             

                               UNITED STATES TAX COURT                                

             WILLIAM H. MANSEL, JR. AND ANGELA W. MANSEL, Petitioners v.              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 286-04S.               Filed October 31, 2005.              

               William H. Mansel, Jr., pro se.                                        
               Horace Crump, for respondent.                                          

               COUVILLION, Special Trial Judge:  This case was heard                  
          pursuant to section 7463 of the Internal Revenue Code in effect             
          at the time the petition was filed.1  The decision to be entered            

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

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