David K. and Alice Vanarsdall - Page 2

                            T.C. Summary Opinion 2005-170                             


                               UNITED STATES TAX COURT                                


                    DAVID K. AND ALICE VANARSDALL, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7943-04S.            Filed November 21, 2005.               

               Vicki L. Anderson, for petitioners.                                    
               Angela J. Kennedy, 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 year at issue.           




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