Basman Ahmad and Khitam Amerneh - Page 2

                            T.C. Summary Opinion 2005-103                             

                               UNITED STATES TAX COURT                                

                   BASMAN AHMAD AND KHITAM AMERNEH, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 266-04S.            Filed July 25, 2005.                    

               Basman Ahmad and Khitam Amerneh, pro se.                               
               John W. Strate, 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, all subsequent section                    
          references are to the Internal Revenue Code in effect for the               
          year in issue.                                                              

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