T.C. Summary Opinion 2005-183                             
                               UNITED STATES TAX COURT                                
              JEFFREY THOMAS OLUP AND LOUISE MARIE OLUP, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 7925-05S.              Filed December 13, 2005.             
               Jeffrey Thomas Olup, pro se.                                           
               Russell F. Kurdys, for respondent.                                     
               ARMEN, Special Trial Judge:  This case was heard pursuant to           
          the provisions of section 7463 of the Internal Revenue Code in              
          effect when the petition was filed.1  The decision to be entered            
               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2002,             
          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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