Paul M. and Wanda E. Harmon - Page 2















                         T.C. Summary Opinion 2007-127                                


                               UNITED STATES TAX COURT                                


                     PAUL M. AND WANDA E. HARMON, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11911-06S.            Filed July 26, 2007.                  

               Wanda E. Harmon, pro se.                                               
               Emily Giometti, 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  Pursuant to section                   
          7463(b), the decision to be entered is not reviewable by any                



               1  Unless otherwise indicated, all subsequent section                  
          references are to the Internal Revenue Code in effect for 2001,             
          the taxable year at issue, and all Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      





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