Bonnie J. and Ernest R. Werts - Page 2

                            T.C. Summary Opinion 2005-24                              


                               UNITED STATES TAX COURT                                


                    BONNIE J. AND ERNEST R. WERTS, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No.  5160-03S.              Filed March 1, 2005.                

               Bonnie J. and Ernest R. Werts, pro se.                                 
               Fred E. Green, Jr., 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.                          



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





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