John and Kristine Wolfgram - Page 2

                            T.C. Summary Opinion 2005-116                             


                               UNITED STATES TAX COURT                                


                     JOHN AND KRISTINE WOLFGRAM, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7152-04S.            Filed August 8, 2005.                  

               John and Kristine Wolfgram, pro se.                                    
               Thomas D. Greenaway, 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            
          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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