Gunasundran R. Pillay and Kalaivani Govender - Page 2

                         T.C. Summary Opinion 2006-93                                 



                               UNITED STATES TAX COURT                                


            GUNASUNDRAN R. PILLAY AND KALAIVANI GOVENDER, Petitioners v.              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 5872-04S, 17168-04S.  Filed June 8, 2006.                  


               Gunasundran R. Pillay and Kalaivani Govender, pro sese.                
               Margaret A. Martin, for respondent.                                    


               PANUTHOS, Chief Special Trial Judge:  These cases were heard           
          pursuant to the provisions of section 7463 of the Internal                  
          Revenue Code in effect at the time the petitions were filed.  The           
          decisions to be entered are not reviewable by any other court,              
          and this opinion should not be cited as authority.  Unless                  
          otherwise indicated, subsequent section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             





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