Richard J. Sarni and Susan Sarni - Page 2

                            T.C. Summary Opinion 2005-189                             

                               UNITED STATES TAX COURT                                

                  RICHARD J. SARNI AND SUSAN SARNI, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23540-04S.           Filed December 29, 2005.               

               Richard J. Sarni and Susan Sarni, pro sese.                            
               Jamie J. Song, 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            
          is not reviewable by any other court, and this opinion should not           
          be cited as authority.                                                      

               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2000,             
          the taxable year in issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      

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